Dear User,

We would like to inform you that this page describes the general principles of administration of the www.lacoste.hu website, which is administered by Devanlay Polska Sp. z o.o. with its registered office in Warsaw (00-120 Warsaw), ul. Złota 59, NIP number: 7010341947, REGON number: 146127374, registered in the Register of Entrepreneurs kept by the District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division, under the KRS number 0000419724, with a share capital of PLN 13,038,100.00, with regard to the personal data of users who visit it. These rules apply in all cases of visiting our websites without registration or completing or entering data in web forms.

By visiting the pages of this website, you accept the terms and conditions listed below. If you do not accept the terms and conditions, please do not visit or use the content of the services offered through our websites.

PRIVACY POLICY AND COOKIES

GENERAL PRINCIPLES

1. This Privacy Policy document and Cookies contain information considering:

a. methods and principles of processing and protecting personal data of the http://www.lacoste.hu website users (“Website”) administrated by Devanlay Polska Sp. z o.o. with its registered office in Warsaw (00-120 Warsaw), ul. Złota 59, NIP number: 7010341947, REGON number: 146127374, registered in the Register of Entrepreneurs kept by the District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division, under the KRS number 0000419724, with a share capital of PLN 13,038,100.00; (“Devanlay”), e-mail: gdpr@lacoste.pl , (“Privacy Policy”);

b. cookies (“Cookies”).

2. The Privacy Policy and Cookies indicate the principles of conduct in all matters relating to the processing and protecting of personal data in the meaning given by the provisions on personal data protection, including in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (Official Journal of the European Union L 119, p. 1) ("GDPR") and the Personal Data Protection Act of 10 May 2018 ("Personal Data Protection Act"). These principles are also consistent with the Act on Provision of Electronic Services of 18 July 2002, as well as with the Act on Telecommunications Law of 16 July 2004.

3. NOTE: We would like to inform you that the Website may contain external links that allow users to directly access other websites. Devanlay has no control over the privacy policies and use of Cookies on other websites and shall not be liable for them. We suggest that before using the resources offered by other websites, please read the document of privacy policy and use of Cookies, if available, or, if not available, contact the owners of the website to get information about this matter.

4. Devanlay declares that the content of the Website shall not violate any third party rights or applicable law regulations and, in particular, shall be free from content containing information that could cause or threaten the privacy or safety of any person, information, which promote illegal activities or behaviours which are offensive, pose a threat, are obscene, defamatory or libellous, incite to racism, prejudice on grounds of ethnic origin, culture, or religious beliefs, which promote or facilitate criminal activities, violate the rights of third parties, including intellectual property rights, or otherwise constitute a violation of rights protected by law.

5. Each person visiting the Website automatically becomes a User ("User"). By using the Website or providing personal information, the User shall accept the principles described in this Privacy Policy and Cookies. In case of lack of consent to the content of the Privacy Policy and Cookies, the User shall not use the Website or transfer personal data to Devanlay.

6. In certain cases, specific information about the privacy protection shall be provided additionally or the User shall be asked to give specific, voluntary consent, directly at the place and at the time when it provides its personal information to Devanlay or interacts with Devanlay.

PERSONAL DATA CONTROLLER

The personal data controller shall be Devanlay Polska Sp. z o.o. with its registered office in Warsaw (00-120 Warsaw), ul. Złota 59, NIP number: 7010341947, REGON number: 146127374, registered in the Register of Entrepreneurs kept by the District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division, under the KRS number 0000419724, with a share capital of PLN 13,038,100.00 („Controller”).

In order to exercise the rights and obtain further information concerning the processing of data, as well as information on whether and to what extent personal data are being processed, interested persons may contact the Controller by writing to the address gdpr@lacoste.pl.

The Controller has appointed a Data Protection Officer available at the address gdpr@lacoste.pl or by mail at Devanlay Polska Sp. z o.o. ul. Złota 59, 00-120 Warsaw.

PERSONAL DATA

Personal data shall mean information on an identified or identifiable individual (“data subject”) (“personal data”). An identifiable individual is a person who may be identified, directly or indirectly, in particular on the basis of an identifier such as name and surname, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the individual. Personal data may also include unique numerical identifiers, such as the IP address of the User's computer or the MAC address of the User's mobile device, as well as Cookies.

PRINCIPLES OF PERSONAL DATA COLLECTION

Personal data concerning the User may be collected by Devanlay from a number of sources, including:

a. provided directly by the User

Devanlay collects information about how the User uses our services and products, e.g., information about the types of content that the User is viewing or dealing with, and the frequency and duration of the User's activities. Devanlay also collects the personal data provided when registering for the Newsletter, registering to purchase our products and completing surveys.

b. personal data collected by Devanlay automatically

Devanlay also receives and stores certain types of personal data each time the User contacts Devanlay online. Personal data shall be also collected during searching, shopping, participating in contests and surveys, and communicating with our customer service teams.

c. personal data collected by Devanlay from other sources

We collect personal data from other sources, e.g. from our trusted external partners and external platforms where Devanlay has accounts (e.g. Facebook).

This website is designed and intended for adult Users.

Devanlay does not intentionally acquire or collect personal data from children under the age of 18. In case of discovering that Devanlay has accidentally collected personal data from children under the age of 18, the data shall be deleted immediately.

PERSONAL DATA STORAGE

The personal data collected by Devanlay is stored and processed in the European Economic Area ("EEA"). Devanlay shall inform that these data may also be transferred to a country outside this area and processed there by entities related by capital to Devanlay or third parties who support Devanlay in the provision of services offered.

For such operations, for entities based in countries where the European Commission has not found an adequate level of data protection, Devanlay shall use Standard Contractual Clauses, approved by the Commission as a means of securing the compliance of the operations with applicable law regulations, and data processing agreements that meet the requirements of the GDPR.

TRUSTED PARTNERS

Limited processing of personal data may involve the Devanlay’s trusted partners ("Trusted Partners"), in particular those who technically assist in the smooth running of the Website or Online Shop, hosting or ICT service providers, carriers or intermediaries performing order shipments, entities handling electronic payments or payment card payments in the Online Shop, companies that service the software, support Devanlay in marketing campaigns, as well as legal, accounting and advisory service providers.

With the Trusted Partners who have their registered office outside the EEA, Devanlay has signed the Standard Contractual Clauses, approved by the Commission.

Devanlay cooperates with external courier companies for delivery. These courier companies shall receive the following data in order to carry out a specific order:

· Name and surname of the User

· delivery address

· or postal number (if the order is to be delivered to the parcel locker)

· or e-mail address (if the courier company wants to inform the user via e-mail about the scheduled delivery)

· phone number (if the courier company wants to inform the user by phone or text message about the scheduled delivery)

In order to provide services to the Users, Devanlay shall also cooperate with technical service providers. If these entities process the Users' data outside the EOA, Devanlay shall ensure that the service provider in question has contractually or otherwise guaranteed an equivalent level of data protection.

In case of obligations imposed by offices or courts or for the purpose of legal or criminal prosecution, Devanlay shall provide the Users' data to the law enforcement authorities or other third parties, if necessary.

SCOPE OF PERSONAL DATA, PURPOSES AND LEGAL BASIS FOR PROCESSING PERSONAL DATA

The purpose and scope of personal data processed by Devanlay result each time from a specific legal basis defined by the GDPR. In some cases it is the User's consent, in other cases law regulations, sometimes it is a necessity to implement an agreement or a legitimate legal interest of the Controller. The detailed information are presented below.

The most frequent purposes of processing the Users' personal data by Devanlay are, in particular: conclusion and execution of the Service Agreement for the Customer's Account or taking action at the request of the future Customer prior to its conclusion; conclusion and execution of the Sales Agreement or taking action at the request of the future Customer prior to its conclusion; acceptance and processing of complaints; conducting the contest, in particular, selecting the winners of the contest and execution of prizes; presentation of advertisements, offers or promotions (discounts) concerning the Devanlay’s products or services, implementation of the Newsletter service, assessment and analysis of activity and information about the User, including in the framework of automated processing of personal data (profiling), in order to present general advertisements, offers or promotions (discounts) concerning the Devanlay’s products or services, in a manner adjusted to the interests of a given User (without, however, significantly affecting its decisions), in particular for the purpose of implementing the Newsletter service agreement, as well as market and statistical analyses; pursuing claims and defending against claims, including those of third parties; fulfilling legal obligations arising from law regulations, e.g. tax and accounting regulations, especially in the case of payable agreements or maintaining correspondence with the User, including responding to the User's messages.

Devanlay processes personal data only for specific and limited purposes, including in particular:

a. THE CUSTOMER’S ACCOUNT SERVICE

CATEGORIES OF DATA TO BE PROCESSED: contact details such as name and surname, address, country, e-mail address and phone number, User ID, password, date of birth, account settings, and, if the User makes purchases, also payment information and payment history, information on orders, deliveries, order history, encrypted credit card data (without CVV or CVC security code), personal data related to Cookies, in particular, click history and navigation and browsing history, and, if the User requests a VAT invoice, also NIP and REGON numbers. During the CUSTOMER'S ACCOUNT service Devanlay may also process such personal data as age (to check if the User is of legal age) or gender (to properly address the correspondence). The Customer's Account of a registered User may be closed at any time by contacting us through our Customer Service gdpr@lacoste.pl.

PURPOSE: Devanlay processes the above-mentioned personal data in order to perform the Customer's Account service (free of charge electronic service referred to in Article 10.1 b of the Regulations of the Online Shop) and enable the User to use certain functionalities of the Website and provide him/her with access to various functions, products and services which are available to him/her as a registered User, e.g. to be informed individually about changes to the Regulations of the Online Shop or the Privacy Policy and Cookies or about promotions, as well as saving products in the shopping cart. In case of purchase, Devanlay processes the above-mentioned personal data in order to complete orders and returns and send the User notifications about the status of delivery or in case of any problems with the delivery of products, as well as to manage payments or process complaints.

DATA RETENTION PERIOD: Devanlay shall keep the User's personal data for the duration of the agreement on the provision of the Customer's Account service, in which the account shall be active. If the data processing by Devanlay is based on another legal basis indicated below in the section LEGAL BASIS, then the User's personal data shall be stored for the entire period of existence of this legal basis. In any case, a longer period of personal data retention is decisive.

PROVIDING PERSONAL DATA: Devanlay transfers the User's personal data to the Trusted Partners only to those who are responsible for the correct and uninterrupted operation of the Customer's Account and as part of the capital group to which Devanlay belongs. In case of a purchase made by the User, Devanlay transfers the User's personal data to the Trusted Partners, i.e. in particular to courier companies, payment processing companies, companies performing IT services, debt collection companies, law firms, accounting firms, solely to ensure the achievement of the goals specified above.

LEGAL BASIS: The processing of personal data shall take place on the basis of an agreement with the User to open the Customer's Account service or is necessary to take action at the User's request related to the activation of this service (Article 6 sec. 1 letter b) of the GDPR). At the same time, in case of a purchase made by the User or a complaint lodged by him/her, apart from the legal basis indicated above, Devanlay shall also have the right and obligation to process data not less than for the period required by law regulations, including in particular the regulations of tax acts and the Accounting Act (Article 6 sec.1 letter c) of the GDPR). Additionally, Devanlay shall have the right to process the User's personal data when it is necessary for the purposes resulting from legally justified interests exercised by the Controller, i.e. in case of establishing, pursuing or defending against the User's claims (Article 6 sec. 1) letter f) of the GDPR). If the User wishes to use the option of sending him/her direct marketing information, organising contests, promotions, surveys, competitions, loyalty programme, the processing of the personal data takes place on the basis of the User's consent (Article 6 sec. 1) letter a) of the GDPR).

b. THE USER’S ONLINE SHOPPING

CATEGORIES OF DATA TO BE PROCESSED: contact details such as name and surname, address, country, e-mail address and phone number, payment information and payment history, age, gender, country, encrypted credit card data (without CVV or CVC security code) and, if the User requests a VAT invoice, also NIP and REGON numbers. In case the User additionally uses the Customer's Account service, the information on history of orders, delivery, User ID, password and account settings as well as personal data related to Cookies shall also be processed, in particular the click history and navigation and browsing history.

PURPOSE: Devanlay processes the above-mentioned personal data in order to complete orders and returns, to manage the questions about the availability of clothes, product reservations through the Website or to provide personal tailoring services, depending on the availability of these services at a given time and to send the User notifications about the status of delivery or in case of any problems with the delivery of products, as well as to manage payments, for invoicing purposes and to issue receipts and invoices for purchases made through the Website or to process complaints.

DATA RETENTION PERIOD: Devanlay shall store the User's personal data for as long as it is necessary for the User to perform the purchase agreement. If the data processing by Devanlay is based on another legal basis indicated below in the section LEGAL BASIS, then the User's personal data shall be stored for the entire period of existence of this legal basis. In any case, a longer period of personal data retention is decisive.

PROVIDING PERSONAL DATA: Devanlay transfers the User's personal data to the Trusted Partners, i.e. in particular to courier companies, payment processing companies, debt collection companies, law firms, accounting firms, solely to ensure the achievement of the goals specified above and as a part of the capital group to which Devanlay belongs.

LEGAL BASIS: The processing of personal data is necessary to perform the online shopping service or to take action at the User's request prior to concluding an agreement (Article 6 sec. 1 letter b) of the GDPR). At the same time, Devanlay shall also have the right and obligation to process data not less than for the period required by law regulations, including in particular the regulations of tax acts and the Accounting Act (Article 6 sec.1 letter c) of the GDPR). Additionally, Devanlay shall have the right to process the User's personal data when it is necessary for the purposes resulting from legally justified interests exercised by the Controller, i.e. in case of establishing, pursuing or defending against the User's claims (Article 6 sec. 1) letter f) of the GDPR).

c. PROCESSING OF THE USERS' REQUESTS

CATEGORIES OF DATA TO BE PROCESSED: contact details such as name and surname, address, e-mail address and phone number, payment information and payment history, date of birth, age, country, encrypted credit card data (without CVV or CVC security code) and, if the User requests a VAT invoice, also NIP and REGON numbers, correspondence with the User concerning its demands and expectations. In case the User additionally uses the Customer's Account service, Devanlay shall also process information on history of orders, deliveries, User ID, password and account settings, as well as personal data related to Cookies, in particular click history and navigation and browsing history.

PURPOSE: Devanlay processes the above-mentioned personal data in order to answer the User's questions (Article 6 sec. 1 letter a) of the GDPR), process the User's complaints concerning the products and technical questions submitted by e-mail or phone (Article 6 sec. 1 letter a) or b) of the GDPR), as well as in case it is necessary to contact the User in connection with his/her order, delivery of the product, return of the product or shipment of the product (Article 6 sec. 1 letter b) of the GDPR). Devanlay processes the above-mentioned data in order to better understand the needs and expectations of the Users and thus improve its services, products and brands as well as for statistical purposes (Article 6 sec. 1 letter f) of the GDPR).

DATA RETENTION PERIOD: Devanlay shall process the above-mentioned personal data until the User's request is definitively completed. If the data processing by Devanlay is based on another legal basis indicated below in the section LEGAL BASIS, then the User's personal data shall be stored for the entire period of existence of this legal basis. In any case, a longer period of personal data retention is decisive.

LEGAL BASIS: The processing of the User's personal data by Devanlay is necessary for the purposes resulting from the legally justified interests exercised by the Controller, in particular to establish, pursue or defend claims, maintain correspondence with the Users, also through contact forms (including responding to the messages of the Users), market and statistical analyses (Article 6 sec. 1 letter f) of the GDPR). In case of responding to the User's inquiries, the processing of the User's personal data by Devanlay shall take place on the basis of the User's consent (Article 6 sec. 1 letter a) of the GDPR), and in cases connected with the User's notifications resulting from the execution of a sales agreement concluded on-line, the processing may be necessary both for the execution of the agreement (Article 6 sec. 1 letter b) of the GDPR) and subsequently to fulfil the legal obligation imposed on the controller (Article 6 sec. 1 letter c) of the GDPR).

d. THE NEWSLETTER SERVICE

CATEGORIES OF DATA TO BE PROCESSED: contact details such as name and surname, address, gender, country, e-mail address and phone number, User ID, password, age, date of birth, account settings, personal data related to Cookies, in particular click history and navigation and browsing history.

PURPOSE: Devanlay processes the above-mentioned personal data in order to provide the Newsletter service (free of charge electronic service referred to in Article 10.1 a of the Online Shop Regulations) and enable receiving information via e-mail about new services or products offered by Devanlay. For more information please go to the section concerning Profiling.

DATA RETENTION PERIOD: Devanlay shall store the User's personal data during the term of the Newsletter service agreement. If the data processing by Devanlay is based on another legal basis indicated below in the section LEGAL BASIS, then the User's personal data shall be stored for the entire period of existence of this legal basis. In any case, a longer period of personal data retention is decisive. If the User refuses to receive individual product proposals from Devanlay by e-mail, it is possible for the User to cancel this service in any form, e.g. by e-mail, at any time, without incurring costs other than the cost of providing information according to basic tariffs (e.g. Internet connection costs, postal charges).Of course, there is a cancellation link in every e-mail. If the User refuses to receive individual product proposals from us using the push service, the User may deactivate this function at any time in the settings of particular application. In most of our applications, a specific function is available in the "Settings" section, in the "Notifications" or "Push messages" menu.

PROVIDING PERSONAL DATA: Devanlay provides the User's personal data to the Trusted Partners, only to those who are responsible for the correct and uninterrupted operation of the Newsletter service.

LEGAL BASIS: The processing of personal data shall take place on the basis of an agreement with the User to open the Newsletter service or to take action at the User's request related to the activation of this service (Article 6 sec. 1 letter b) of the GDPR). Additionally, Devanlay shall have the right to process the User's personal data when it is necessary for the purposes resulting from legitimate interests exercised by the Controller, i.e. in case of establishing, pursuing or defending against the User's claims (Article 6 sec. 1 letter f) of the GDPR).

e. THE CONTACT FORM SERVICE

CATEGORIES OF DATA TO BE PROCESSED: contact details such as name, e-mail address and phone number, age, date of birth, personal data related to Cookies, in particular click history and navigation and browsing history.

PURPOSE: Devanlay processes the above-mentioned personal data in order to provide the Contact Form service (free of charge electronic service referred to in Article 10 c of the Online Shop Regulations) and allow the User to send messages to Devanlay through the form available on the Online Shop website.

DATA RETENTION PERIOD: Devanlay shall store the User's personal data during the term of the Contact Form service agreement. If the data processing by Devanlay is based on another legal basis indicated below in the section LEGAL BASIS, then the User's personal data shall be stored for the entire period of existence of this legal basis. In any case, a longer period of personal data retention is decisive.

PROVIDING PERSONAL DATA: Devanlay provides the User's personal data to the Trusted Partners, only to those who are responsible for the correct and uninterrupted operation of the Contact Form service.

LEGAL BASIS: The processing of personal data shall take place on the basis of an agreement with the User to open the Contact Form service or to take action at the User's request related to the activation of this service (Article 6 sec. 1 letter b) of the GDPR). Additionally, Devanlay shall have the right to process the User's personal data when it is necessary for the purposes resulting from legitimate interests exercised by the Controller, i.e. in case of establishing, pursuing or defending against the User's claims (Article 6 sec. 1 letter f) of the GDPR). Responding to the User's inquiries shall take place on the basis of the User's prior consent to the processing of personal data (Article 6 sec. 1 letter a) of the GDPR).

f. CONTESTS

CATEGORIES OF DATA TO BE PROCESSED: contact details such as name and surname, e-mail address and phone number, age, date of birth, personal data related to Cookies, in particular click history and navigation and browsing history as well as information provided in the contest.

PURPOSE: Devanlay processes the above-mentioned personal data on the basis of the User's consent which the User gives when applying for participation in the contest. The User's personal data shall be used to enable Devanlay to contact the Participant in matters relating to the contest, before and after the event, in order to establish the identity of the Participants and verify their age, in order to contact the winners and to deliver the prize and determine the delivery method.

DATA RETENTION PERIOD: Devanlay shall store the User's personal data for a period of 100 days after the end of the contest.

PROVIDING PERSONAL DATA: Personal data shall be transferred by Devanlay to the Trusted Partners, i.e. to external companies exclusively in order to provide the above-mentioned services and enable courier companies to deliver the prizes.

LEGAL BASIS: The processing of personal data is subject to the User's consent (Article 6 sec. 1 letter a) of the GDPR). Additionally, Devanlay shall have the right to process the User's personal data when it is necessary for the purposes resulting from legitimate interests exercised by the Controller, i.e. in case of establishing, pursuing or defending against the User's claims (Article 6 sec. 1 letter f) of the GDPR).

g. DIRECT MARKETING OF THE DEVANLAY PRODUCTS

CATEGORIES OF DATA TO BE PROCESSED: In case the User uses the Customer's Account service, Devanlay processes contact details such as name and surname, e-mail address and phone number, age, date of birth, gender, purchase history, personal data related to Cookies, especially click history and navigation and browsing history. In other cases, Devanlay processes contact details such as e-mail address, phone number and postcode, gender (if the User provides such information) and details of products and offers opened on the Website by the User.

PURPOSE: Devanlay processes the above-mentioned personal data in order to send marketing offers, surveys and invitations to the User - by e-mail, text message, phone and traditional mail.

DATA RETENTION PERIOD: Devanlay shall store the User's personal data only during the period of the User's valid consent.

PROVIDING PERSONAL DATA: Personal data shall be transferred by Devanlay to the Trusted Partners, i.e. to external companies, exclusively in order to provide direct marketing services to Devanlay. These data shall never be made available to third parties.

LEGAL BASIS: The processing of personal data shall take place on the basis of the User's consent (Article 6 sec. 1 letter a) of the GDPR). Additionally, Devanlay shall have the right to process the User's personal data when it is necessary for purposes resulting from legitimate interests exercised by the Controller, i.e. in case of establishing, pursuing or defending against the User's claims (Article 6 sec. 1 letter f) of the GDPR).

The User shall have the right to withdraw its consent to the processing of personal data and receiving direct marketing materials at any time.

Upon withdrawal of the consent, Devanlay shall not send the User any offers in the framework of direct marketing or information previously sent on the basis of the consent to the processing of data.

h. ONLINE SEARCH

CATEGORIES OF DATA TO BE PROCESSED: depending on the frequency of the User's online interaction with DEVANLAY, these data may include the use of the Website, data about the User's origin, login details, websites visited by the User, videos viewed by the User, advertisements marked by the User, products that the User was looking for, the User's location, duration of the User's visit, products selected by the User for the shopping cart, IP address, browser information, unique identifier assigned to each visitor and the expiry date of such identifier.

PURPOSE: Devanlay processes the above-mentioned personal data in order to enable proper functioning of the Website, proper display of its content, creation and remembering the card; creation and remembering the User's login, personalisation of the interface, such as selection of the language, the User's device parameters, as well as in order to ensure security of the Website and for statistical purposes.

DATA RETENTION PERIOD: Devanlay shall store the User's personal data only during the period of a valid legal basis indicated below in the LEGAL BASIS section.

LEGAL BASIS: The processing of personal data related to Cookies shall take place due to the legitimate interest of the Controller (Article 6 sec. 1 letter f) of the GDPR), i.e., among others, to maintain the security of the Website and enable its functioning. In case the purpose is to improve offers or services of Devanlay or to send advertisements or to provide matching content, the processing shall take place on the basis of the User's consent (Art. 6 sec. 1 letter a) of the GDPR).

i. NOTIFICATION OF PRODUCT AVAILABILITY

CATEGORIES OF DATA TO BE PROCESSED: the User's e-mail address, the User's phone number, the User's name and surname and the data that the User has been looking for and that are available.

PURPOSE: Devanlay processes the above-mentioned personal data at the User's request in order to send the User electronically or by phone information about the availability of products indicated by you. The condition of sending such information by Devanlay shall be consent to receiving commercial information about the products of the online shop to the given e-mail address and processing of personal data by Devanlay or giving consent on the form provided by Devanlay.

DATA RETENTION PERIOD: Devanlay shall store the User's personal data only during the period of the User's valid consent.

LEGAL BASIS: Providing the data is voluntary, however, the lack of consent to the processing of personal data makes it impossible to send information about product availability. The processing of personal data shall take place on the basis of the User's consent (Article 6 sec. 1 letter a) of the GDPR). Additionally, Devanlay shall have the right to process the User's personal data when it is necessary for purposes resulting from legitimate interests exercised by the Controller, i.e. in case of establishing, pursuing or defending against the User's claims (Article 6 sec. 1 letter f) of the GDPR).

The User shall have the right to withdraw its consent to the processing of personal data and to receive direct marketing materials at any time.

Upon withdrawal of the consent, Devanlay shall not send the User any information about product availability.

j. RETARGETING

Based on Cookies, we use technology allowing us to deliver advertising messages to users who have already visited our Website, on other websites that they visit, including those belonging to entities cooperating with our partners.

The lack of connection between the advertisement displayed to the User and its interests and needs may be burdensome for the User. Devanlay is aware that it is more attractive and practical for the User to receive a message that matches its interests and needs identified through the analysis of its previous behaviour, based on the cookies technology. Therefore, Devanlay is interested in following the advertising content of a user using different websites in order to provide advertising content adjusted to its previous online activity.

k. IMPLEMENTATION OF THE DEVANLAY'S LEGAL OBLIGATIONS

CATEGORIES OF DATA TO BE PROCESSED: all information about the User required by the provisions of the applicable law depending on the specific regulations or decisions of the competent authorities, in particular name and surname, contact details (e.g. e-mail address, mobile phone number), correspondence; information concerning the time and place of purchase and defects/complaints concerning the product, purchase history, other information. In order to fulfil its accounting and tax obligations, Devanlay shall, in particular, process the following personal data of the Users: contact details such as name and surname, address, payment information and payment history, NIP and REGON.

PURPOSE: Devanlay processes the above-mentioned personal data in order to fulfil its legal obligations only when necessary. Devanlay must process personal data in order to manage the obligations imposed on the company and in order to combat criminal activity and other misuse, or to comply with other legal obligations resulting from law regulations, judgments or official decisions. Such requirements may include, among others, requirements concerning product liability and product safety, such as communication and informing the public and consumers about product warnings and recalls, e.g. in the case of defective products or products that pose a health risk or to the extent required by the provisions of individual acts. Devanlay shall also process the Users' personal data in the order to fulfil the legal obligations resulting from the regulations, e.g. tax and accounting.

DATA RETENTION PERIOD: The processing of data by Devanlay shall take place during the entire existence of this legal basis. In case Devanlay also processes the Users' personal data in order to fulfil the legal obligations resulting from the regulations, e.g. tax and accounting, the retention period shall be 6 years.

PROVIDING PERSONAL DATA: Devanlay transfers the User's personal data to competent authorities and institutions. In case Devanlay also processes the Users' personal data in order to fulfil the legal obligations resulting from the regulations, e.g. tax and accounting, the personal data (mostly aggregated) may also be transferred to the Trusted Partners or made available as part of the capital group to which Devanlay belongs.

LEGAL BASIS: Processing is necessary to fulfil the legal obligation of the controller (Article 6 sec. 1 letter c) of the GDPR). Additionally, Devanlay shall have the right to process the User's personal data when it is necessary for purposes resulting from legitimate interests exercised by the Controller, i.e. in case of establishing, pursuing or defending against the User's claims (Article 6 sec. 1 letter f) of the GDPR).

PROVIDING PERSONAL DATA

Apart from the cases of providing personal data described above, the personal data may also be provided to entities belonging to the same capital group to which Devanlay belongs and to third parties who support Devanlay in the provision of services offered by the company, i.e.:

· financial institutions,

· institutions involved in the detection and prevention of fraud,

· technology service suppliers,

· suppliers and partners in logistics, transport and delivery services,

· customer service providers,

· suppliers and partners in the provision of marketing and advertising services.

In order to maximise the effectiveness of the service provided, some of these service providers are established in countries outside the EEA territory. In such cases, the Users shall be informed of the transfer of their data outside the EEA.

PROFILING

When Devanlay sends or displays personalised information or content (advertisements, offers, promotions, discounts), in such a situation it may use so-called "profiling", i.e. any form of automated processing of personal data, which involves using personal data to assess certain personal factors of an individual, in particular to analyse or forecast aspects relating to personal preferences, interests, economic situation, behaviour, location, health, reliability or movement. This allows Devanlay to better understand the User's expectations and adapt to its needs, without significantly influencing its decisions. Thanks to the Devanlay's use of advanced technologies, the above activities shall often be performed by the system in an automated manner, thanks to which the content sent shall be the most up-to-date and the User shall be able to get acquainted with it quickly (ordinary "profiling").

Only in the case of adult Users, the above-mentioned analysis of interests and preferences performed by Devanlay shall also serve to create, award, implement dedicated and, to the highest possible extent, customised advertisements, offers or promotions (discounts), in an automated manner, which may cause legal effects towards it or significantly affect it in a similar manner, potentially limiting access to them for other Users (option unavailable for Users who are not of age and have not given consent to such Devanlay’s activities). These activities, in contrast to ordinary "profiling", may have a significant impact on the User's purchasing choices. The more often a given User uses the Devanlay’s services and purchases its products, the better promotions and surprises may be prepared for the User.

Under certain circumstances described below, the User shall have the right to object to the use of his/her data for profiling by revoking the consent to profiling or changing the settings of Cookies.

PROVIDING DATA OF THIRD PARTIES BY THE USER

Functions and services offered and provided by Devanlay may require Devanlay to process personal data of third parties provided to Devanlay by the Users.

In case the User provides personal data of third parties, Devanlay assumes that the User has informed these persons about the purposes and manner of their processing.

THE USER’S RIGHTS

The User shall have the right to:

THE RIGHT OF ACCESS TO DATA: The User shall have the right to access its personal data, which are stored by Devanlay according to the principles set forth in the GDPR. Devanlay may require a reasonable fee, taking into account the administrative costs of providing such information. Requests that are manifestly unjustified, excessive or repetitive may remain unanswered. To exercise this right, please contact us at the following e-mail address: gdpr@lacoste.pl.

THE RIGHT TO CORRECT PERSONAL DATA: The User shall have the right to demand the correction of its personal data if they are incorrect or out of date, as well as to fill in incomplete data. In order to exercise this right, please contact us at the following e-mail address: gdpr@lacoste.pl. If the User uses the Customer's Account service, the User may correct or update its personal data itself.

THE RIGHT TO DELETE DATA: The User shall have the right to delete any data processed by Devanlay. This right shall not be exercised by Devanlay in case of, among others, unfinished proceedings within the framework of processing the Users' applications, an open order which has not yet been sent or has been sent only partially, unpaid debt to Devanlay, regardless of the payment method, existence of at least a suspicion that the User has used Devanlay's services in the last three years in an improper manner, making any purchases, because then Devanlay shall store the User's personal data concerning transactions for accounting and tax purposes. To exercise this right, please contact us at the following e-mail address: gdpr@lacoste.pl.

THE RIGHT TO NOT EXPRESS CONSENT TO THE PROCESSING OF DATA ON THE BASIS OF THE LEGITIMATE INTEREST OF DEVANLAY: The User shall have the right not to consent to the processing of his/her data on the basis of the legitimate interest of Devanlay. In such a situation, Devanlay shall stop processing his/her personal data unless it is able to demonstrate a lawful justification for this process that takes precedence over the interest of the User or due to legal claims. To exercise this right, please contact us at the following e-mail address: gdpr@lacoste.pl.

THE RIGHT TO TRANSFER DATA: In case Devanlay processes the User's personal data in an automated manner, on the basis of his/her consent or concluded agreement, the User shall have the right to receive a copy of its data in a structured, commonly used and readable format. This copy may be sent to the User or to another entity. This only applies to personal data that has been provided to Devanlay. To exercise this right, please contact us at the following e-mail address: gdpr@lacoste.pl.

THE RIGHT TO LIMIT THE PROCESSING: The User shall have the right to request that Devanlay limits the processing of his/her data. This right means that the processing of the User's data by Devanlay shall be limited to storage and shall not be used or processed in any other manner. This shall apply in the limited cases specified by GDPR, i.e. (i) the User questions the accuracy of the personal data for a period of time that allows Devanlay to verify the accuracy of the data, (ii) the processing is illegal, and the User objects to the deletion of the personal data, requesting instead a limitation of their use, and (iii) Devanlay no longer needs personal data for the purposes of the processing, but the data are needed by the User to establish, pursue, or defend claims, (iv) the User has objected to the processing based on the legitimate interest of Devanlay - until it is determined whether the legitimate grounds on the part of Devanlay take precedence over the grounds for objection of the User. To exercise this right, please contact us at the following e-mail address: gdpr@lacoste.pl.

THE RIGHT TO OBJECT TO THE AUTOMATED PROCESSING, INCLUDING PROFILING: In order to exercise this right, the User shall click the "unsubscribe" link in any e-mail or message that has been sent to him/her by Devanlay. To object to the profiling, please contact us at the following e-mail address: gdpr@lacoste.pl.

THE RIGHT TO WITHDRAW CONSENT AT ANY TIME WITH REGARD TO THE PROCESSING OF DATA BASED ON CONSENT: The User may withdraw its consent to the processing of his/her data by Devanlay if such processing is based on consent. The withdrawal of consent shall not affect the lawfulness of the processing based on consent before it is withdrawn. To exercise this right, please contact us at the following e-mail address: gdpr@lacoste.pl.

THE RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY: The User shall have the right to contact the data protection authority, i.e. the President of the Personal Data Protection Office in order to lodge a complaint against the activities of Devanlay in the area of data protection and privacy. Devanlay asks Users to contact at the following e-mail address gdpr@lacoste.pl before exercising this right.

THE RIGHT TO DEACTIVATE COOKIES: The User shall have the right to deactivate Cookies. The default settings of browser usually accept cookies, but they may be easily changed in the User's browser. Many Cookies are used to increase usability and improve functionality of websites / applications. Therefore, disabling Cookies may prevent the User from using certain parts of the Website. For further information, Devanlay suggests reading the information provided in the "Help" menu in the browser in use or the information provided under the link http://www.aboutcookies.org

THE RIGHT TO INFORMATION: The User shall have the right to be informed in a clear, transparent and easily understandable manner about how Devanlay uses his/her data and about his/her rights. Devanlay shall ensure that this right is exercised by publishing the Policy on the Website.

All information shall be provided by Devanlay without undue delay - as a rule within one month of receiving the request. If necessary, this period shall be extended by another two months due to the complexity of the request or the number of requests.

In any case, within one month of receiving the request, Devanlay shall inform the User of the action taken and (if applicable) the extension of the period, giving the reason for such a delay.

1. Cookies are small text files that are downloaded to the User's device and used by the User to browse the Website.

2. Cookies collect data on the User's use of the Website.

3. The main purpose of Cookies is to ensure a more personal and interactive use of the Website and to monitor the User's traffic on the Website, for example, by allowing the User to set personal preferences. Cookies are needed in order to facilitate the use of the Website and make it more user-friendly without causing any damage to the device.

4. Cookies used by Devanlay may be divided according to the duration of stay in the User's device used for browsing, origin and purpose. Within the Website, two main types of Cookies are used: session cookies and persistent cookies. Session cookies are temporary files that are stored on the user's terminal device until the user logs out, leaves the website or turns off the software (web browser). Persistent cookies are stored in the user's terminal device for a period of time specified in the parameters of cookies or until the user removes them.

5. Within the Website, the following types of Cookies are used (i) "necessary" Cookies to enable the use of services available on the Website, e.g. authentication Cookies used for services that require authentication within the Website, and (ii) "performance" Cookies to collect information about the use of the Website.

6. Devanlay shall not store sensitive personal data such as address, password, credit or debit card details, etc. in Cookies that it uses.

7. By default, web browsers allow storage and access via Cookies to the devices of end users. The User shall have the right at any time to change the settings concerning the mechanism of Cookies, i.e. to change the conditions of storage and access to the information collected through Cookies. The stored information and access to the information shall not alter the configuration of the end-user's device or the software installed on that device.

8. By using this Website without changing the browser settings to disable Cookies, the User agrees to place Cookies on its device and access the User's end device. The users may at any time change their web browser settings to disable Cookies. For information on changing settings for Cookies, please see the link http://www.aboutcookies.org.

9. The User shall have the right to restrict or disable the use of Cookies by its web browser by changing the settings to disable Cookies or requiring prior consent before Cookies are stored on the device used to browse the Website. In this case, it is possible that the User's use of the website may be less effective. The User may not be able to access some of the content or use some of the Website's features and, in extreme cases, the correct display of the Website's content may not be available.

SECURITY

Taking into account the state of the art, the cost of implementation and the nature, scope, context and purposes of the processing, as well as the risk of violation of the rights or freedoms of individuals with different probability and seriousness of the threat, Devanlay shall apply appropriate technical and organisational measures to ensure the protection of the processed personal data appropriate to the threats and categories of data subject to protection, and in particular shall protect the data against unauthorised access, taking away by an unauthorised person, processing in violation of applicable regulations and alteration, loss, damage or destruction.

Publishing information on the technical and organisational measures used to protect the processing may undermine their effectiveness and thus jeopardise the proper protection of personal data.

Devanlay shall, in particular, apply the following technical measures to prevent the acquisition and modification by unauthorised persons of personal data transmitted electronically:

a. Protection of the data set against unauthorised access.

b. SSL certificate on the Online Shop Website of Devanlay where personal data are provided.

c. Encryption of data used for authorisation of a person using the Online Shop functionality.

d. Access to the Customer's Account only after providing an individual login and password.

FACEBOOK PLUG-IN

Our website contains a plug-in for the social networking site Facebook (Facebook Inc., 1601 Willow Road, Menlo Park, California, 94025, USA). The Facebook plug-in on the Website is marked with a Facebook logo.

This plug-in connects the User directly to the Devanlay’s profile on the Facebook server. In this case, Facebook may be informed that the User has visited the Website from its IP address.

If the User visits the Website while logged in to its Facebook profile, Facebook will register information about this visit.

Facebook shall not pass on to Devanlay information about the collected data and the way they are used. Devanlay also does not know the purpose and scope of the data collected by Facebook. For further information about privacy on Facebook, the User should contact Facebook directly or refer to the Facebook privacy policy at the following address: https://www.facebook.com/about/privacy/

If the User does not agree that Facebook may collect information about his/her visits to the Website, the User should log out of his/her Facebook account in advance.

DATA PROTECTION IN GOOGLe Analytics

The Website uses mechanisms of network service analysis of Google Inc. (”Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA “): Google Analytics, Google Double Click and Google Tag Manger. Google Analytics, Google Double Click and Google Tag Manger use cookies to analyse how websites are used. The information collected by cookies is transferred to Google's servers located in the USA and archived.

If the IP address anonymisation feature is activated when using the Website, the User's IP address is shortened by Google. This applies to the Member States of the European Union and other countries listed in the EEA Agreement. Only in exceptional cases the full IP address is sent to a Google server in the USA and shortened there. This way the IP anonymisation feature will be active on the Website. At the request of the website operator, Google uses the information collected to analyse the use of the website, prepare reports on the use of the website and other services related to the use of the Internet. The IP address provided by the User's browser as part of the Google Analytics programme is not stored together with other Google data.

The User may block the storage of Cookies in the web browser. However, in such a case, it is not possible to make full use of all functions of the website. Furthermore, the User may block the storage of the data collected by cookies concerning the use of the website (including the IP address) and the sending of these data to Google, as well as the transmission of these data by Google, by downloading and installing the plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=pl

AMENDMENTS AND UPDATES

Devanlay shall reserve the right to amend or update the Privacy Policy and Cookies.

The latest version shall be available on the Website.

Additionally, the Users who use the Customer's Account service shall be informed individually about amendments to the Privacy Policy and Cookies.

The Privacy Policy and Cookies shall come into force from 25.05.2018.

Latest update: 05.08.2020.