Kopar, provided by Ltd. IBaltica, Company code: 304065920, address: Verkių Sodų 5-oji g. 7, LT-08429 Vilnius, Lithuania (hereafter ‘we’) protect the Personal Information / Data of our customers (hereafter ‘You’) by applying the highest technical and legal protection standards in accordance with the Law on Legal Protection of Personal Data of the Republic of Lithuania, Law on Electronic Communications of the Republic of Lithuania, EU laws on the protection of personal data and other related legislation and regulations of controlling authorities.
Kopar does not employ a Data Protection Officer. If You have any questions or concerns regarding privacy or if You have any enquires regarding the personal data You have given us, we kindly ask you to contact Kopar at any time. For details on how to contact us, please see “Contact Information” or send us an email at: email@example.com.
1. General Information
Kopar uses information from our interactions with You and other customers as well as certain third parties to help achieve providing the highest quality products and services.
Kopar respects the privacy rights of our online visitors and recognizes the importance of protecting the information collected about them. To this end, we have established procedures that ensure Your personal data is processed in a responsible manner.
2. Personal Data We Collect, Store and Use
All our activities are based on stringent ethical principles and legal requirements, and we are committed to protecting the privacy of all visitors to our website. For this reason, the way in which we collect and store information, including personal data, is dependent on how our website and related services are used. We do not collect any sensitive data about You.
2.1. Data collected through Your interaction with us
Various technologies may be used on our website in order to improve it, make it more user-friendly, efficient and secure. Such technologies may lead to personal data being collected automatically by us or by third parties on our behalf. Examples of such technologies include cookies, flash cookies and web analytics.
2.1.1. Click-stream data
When You visit our website, data is sent from Your browser to our server. This data makes it possible for us to optimize our services and improve Your experience on our website. The data is automatically collected and stored by us or by third parties on our behalf.
We may collect information about Your computer for system administration purposes as well as to report aggregate information for internal marketing analysis reasons. This is data about our users’ browsing actions and patterns and may include the following:
- Visitor’s IP address.
- Geographical location.
- Date and time of the visit.
- Referral URL (the website from which the visitor has been referred).
- Pages visited and user journey on our website.
- Information about the browser used (type, version, operating system, etc.).
2.1.3. Re-targeting Technologies
Our website uses re-targeting technologies. This enables us to advertise directly and personally to visitors who have already showed an interest in our products and/or shop via our partner websites.
We also work with companies who use tracking technologies to serve ads on our behalf across the Internet. These companies may collect information about Your visits to our website, as well as Your interaction(s) with our communications, including advertising.
2.2. Data provided by You
In addition to the data collected by automated means (see 2.1.), we also process data which You have provided to us. This includes but is not limited to:
- Personal data that identifies You as an individual – namely, Your contact information, including Your first and last name(s), address(es), phone number, email address, credit or debit card information, VAT number (for companies), registering for newsletters. If You provide us with the personal data of another person, please make sure that You have the right to share this information with us, as we consider that You have duly received the consent of that person for the submission of his / her personal data.
- Information provided by You at the time of registration for a Kopar account.
- Information provided when You create a Wish List, save Your sizes, save designs.
- Information You provide to us via third parties such as (yet not limited to) Facebook, Instagram, Pinterest, Googleand WeChat.
- Information that You upload to or share through our website by using our services.
- If You have created an online account with us: the preferences and interests stored in this profile (please see below for further information regarding these profiles).
- If You contact us, we may keep a record of Your correspondence.
- If You contact us to report a problem with our website or for technical and/or customer support, we may keep a record of Your correspondence or conversation.
- If we choose to participate in any Alternative Dispute Resolution (ADR) procedure accessible through the ODR Platform, we may disclose personal data to the European Commission in their capacity as operator of the ODR platform, and to any ADR provider appointed to deal with the dispute.
Your personal data may only be accessible to a limited range of the employees of our company, third parties network and the entities providing IT, marketing, and legal services to our company, and only to the extent that is necessary to implement the proper processing of Your personal data, and all of these persons will be subject to strict requirements for the protection of confidential information.
3. Cookies, Signals and Similar Technologies
It is our goal to be transparent about the cookies we use on our website, how we use them, and to give You the necessary tools to manage them. A cookie is a small text file that is placed on Your computer and stores information about how You use our website, in order to provide You the best online experience possible.
A cookie remembers what You have done, including the products You have placed in Your basket, Your preferences, Your account login information, and allows for several other functionalities such as sharing pages on social networks to work. Furthermore, cookies allow us to understand how internet users navigate on our website, what works and what does not, and to make continuous improvements accordingly. Several examples of cookie usage:
- Cookies allow the identification of the number of unique users browsing the website at the same time, thus helping to ensure a smooth and fast functioning of the website.
- Cookies allow analyzing the collected information about unique user browsing, which helps to customize the website to Your needs.
Furthermore, a cookie is not a computer program and cannot be used to circulate viruses. Therefore, a cookie is not dangerous.
There are several types of cookies:
- Session cookies are temporary files that will be erased from Your computer’s memory when You close Your browser or log off the website. Session cookies allow users to be recognized for the duration of a single session so that any page changes or item selection are remembered when they move from page to page. These cookies make navigating across numerous website pages faster and easier, because there is no need to repeatedly process the information when a new page is opened.
- Long-Term / Permanent cookies will usually remain on Your computer’s memory until You manually erase them. They are stored on Your computer for a specified period of time following the end of Your session and they may be record specific user settings or actions when the user returns to the website.
- First-Party Cookies are placed on Your computer by Koper website, as they are essential to the proper functioning of www.kopar.lt website.
- Third-Party Cookies are those placed on behalf of Kopar website by our trusted partners. For instance, in our case, the Google Analytics cookies used on www.kopar.lt website are utilized to analyze the website traffic. Google Analytics collects anonymous information about the number of users, the location from which our website has been accessed, and the parts of the website browsed by the users. These cookies are created by Google Analytics. To learn more about Google Analytics, please visit http://www.google.com/analytics.
In addition, Kopar may use plug-ins from social media networks such as Facebook, Twitter, Youtube, Pinterest or Instagram on its website. In the default setting of the website plug-ins are deactivated; the user can thus choose when to activate them. Should the user do so, the social media providers are able to establish a direct connection to the user during her visit on the website, which allows the provider to be aware of the user’s visit and may analyze the respective information. The subsequent processing of the personal data will be conducted in the responsibility of the social media provider pursuant to data protection and privacy laws and according to its data protection policies published on its website (such as www.facebook.com/; www.twitter.com/; www.youtube.com/; www.google.com/; www.pinterest.com/; www.instagram.com/). Any information collected using cookies is stored until these cookies expire and is not used for any purpose other than those listed in this policy.
3.2. The Types of Cookies Used on Our Website
- Strictly necessary cookies are essential in order for our website to be able to perform its core functions. These cookies allow You to browse the website and use the features You want, such as providing access to the secure areas of the website. Without these cookies, we would not be able to provide the services that allow this website to function.
- Performance cookies collect anonymous information about how visitors use the website. By providing information about the areas visited, the time spent on the website and any problems encountered, such as error messages, these cookies help us understand the behavior of the visitors to the website. This information helps us improve the performance of the website.
3.3. Data We Collect with a Help of Cookies
- When administering websites and diagnosing problems in servers, we can use the IP addresses of visitor computers. An IP address is a unique network code identifying a computer. It can be used to identify a visitor and collect different demographic information. This is done by the absolute majority of web server administrators.
3.4. How to Manage and Delete Cookies
3.6. List of the Cookies We Collect on Our Website
The first type of cookies: We inform You that when You access our website in order to use it the following cookies specified in the table below shall be stored on Your computer:
|Name of the Cookie||Purposes of Data Processing||Creation Moment / Expiry Date||Data Used|
|CMSSESSIDX||A standard cookie used to manage the user’s session||Upon opening the website / Until the user closes the website||Unique identifier|
|cookiesLevelX||A cookie identifying the types of cookies You have accepted on our website||From the time of consent / Until it is deleted||Unique identifier|
|_ga||This cookie is used by Google Analytics to assess the purpose of the user’s visit, generate reports on the website activity to website operators, and improve user’s experience when browsing on the website||From the time of consent / 2 years||Unique identifier|
|_gat||This cookie is used by Google Analytics to collect statistical information about the website traffic||Upon the first visit to the website / until the end of the session||Unique identifier|
|_gid||This cookie is used by Google Analytics to distinguish You from other users||Upon the first visit to the website / 2 days||Unique identifier|
The above cookies are for information transfer over an electronic communications network. You may delete or block all or some of these cookies by Your browser settings, however, it may happen that in this case some features of our website will not work.
The second type of cookies is to collect the website traffic-related information (to collect statistical information), provide the content that matches visitors’ interests, and preserve the history of visits. Our website does not use this type of cookies but it does draw the attention of our visitors to the fact that some of our partners may use this type of cookies, therefore, if the visitor suspects that this type of cookies is used without his / her consent, such a visitor should contact the specific partner.
4. How We Use Your Personal Data (Purpose)
When You have registered for a Kopar account, we may process Your personal data in the following ways:
- Ensure that content from our website is presented on Your computer in the most efficient manner.
- For purposes relating to Your order; e.g. to notify You on the status of Your order or delivery; to fulfil Your requests, such as responding to a question regarding our products; to help You locate a store near You; to fulfil Your order; to process Your payment card and/or to provide You with customer service. We may use Your data to assess Your creditworthiness, for which we may use third parties.
- Verification of Your identity and to respond to any query You may raise with us; to process Your request and provide You with the best service possible.
- To carry out our obligations arising from any contracts entered into between You and us.
- To allow You to participate in the interactive features of our service(s) when You choose to do so.
- To notify You about changes to our services, terms, conditions and policies, and/or other administrative information.
- To provide You with the benefits and services of being a Kopar account holder.
- To administer and maintain our records.
- To store any Wish List You may create and to allow You to share Your Wish List with others.
- To save Your ring and bracelet sizes and to allow You to share them with others.
- To allow You to send emails to others through our “send to a friend” functionality.
- To allow You to participate in sweepstakes, contests and similar promotions as well as to administer such activities. Some of these activities have additional rules which could contain additional information about how we use and disclose Your personal information.
- Customize Your content on our websites to provide You with personalized offers.
- Prevent and/or detect any misuse or fraud.
- With Your permission, we may contact You directly through the details provided by You (e.g. postal services, email, text message, telephone or any other electronic means) for marketing, advertising and market research purposes. For example, this includes information related to Kopar products, e-commerce activities, special offers and promotions, as well as information on local store openings and activities. In order to be able to contact You with information that is of special interest to You, Your overall interaction with Kopar (such as, but not limited to, Your shopping behavior on our online store and in physical Kopar stores; Your use of loyalty programs; Your ratings and reviews of products; Your contact history with our customer service; Your newsletter clicks/opening results; Your surfing behavior (web tracking); the types of newsletter You are subscribed to; Your participation in promotions or events) will be jointly analyzed and used. We may use Your personal data for marketing, advertising and market research purposes. In paragraph 7 You will find information on Your rights, e.g. how to withdraw Your consent or amend Your personal details.
When You visit Kopar website, Your personal data may be processed in the following ways:
- Content, A/B testing and product browsing analytics
- Traffic source analytics
- Internal search analytics
- Purchase analytics
- Device analytics
- Marketing re-targeting
5. Legal Basis
When You purchase an item in our online store, create an account with us, or enter into any other form of agreement with us, we will process Your conventional personal data for that particular purpose. We may also process Your conventional personal data if You e.g. have a query or similar that precedes Your decision to enter into an agreement with us.
The legal basis for which we may process Your personal data is stated in Article 6 1, b) of the EU Personal Data Regulation (EU) 2016/679 (GDPR), as the processing of Your information is necessary for us to fulfil our agreement with You or for us to handle Your inquiries and such like, ahead of concluding an agreement.
We may also process Your ordinary personal data on the basis of the rules in the GDPR Article 6 1, f) unless our interests are outweighed by Your privacy rights and statutory freedom. We have a legitimate interest in processing Your personal data (name and email address) for both marketing and analytical purposes. Our legitimate interest is based on Your preferences so that we can better customize our offerings to You – and ultimately offer products and services that better meet Your needs and wishes. Additionally, we have a legitimate interest in processing Your personal data for analytical purposes.
6. Disclosure of Your Personal Data
Treating Your data with the utmost care and confidentiality is one of our core values. If required by law, Your data may be disclosed to third parties. We employ service providers and data processors to process data on our behalf. These services include authentication, hosting and maintenance services, analysis services, e-mail messaging services, delivery services, handling of payment transactions, solvency, address and e-mail checks. These third parties are our data processors and may only process personal data to the extent necessary in order to deliver their services. Our data processors are contractually obliged to treat such information in the strictest confidence. They are prohibited from using the data in any other way than required. Necessary steps are taken to ensure that our data processors, including service providers and other processors working on behalf of Kopar, uphold and protect the confidentiality of Your data.
Some of our data processors are situated outside the EU/EAA. Consequently, we will share Your personal data with countries outside the EU/EEA. However, we will only provide this information on the basis of the recipient fulfilling the applicable requirements, including:
- The country in question is considered a safe third country.
- The supplier in question shall accede to the European Commission’s Model Contracts for the transfer of personal data to third countries.
- The supplier in question is certified according to Art. 40 of GDPR; or
- The supplier in question has a set of approved Binding Corporate Rules.
There may be occasions on which we disclose to our partners non-personal data in an anonymous form. Such non-personal data may include information about the number of visitors to a website during a certain period of time.
Please note that any information You post or disclose through Your interaction with Kopar (e.g. personal data contained in the photos, stories, comments and videos that You submit) will become public information and may be available to visitors to the website as well as to the general public.
If we choose to participate in any Alternative Dispute Resolution (ADR) procedure accessible through the ODR Platform, we may disclose Your personal information to the European Commission, as operator of the ODR platform, and to any ADR provider appointed to deal with the dispute.
7. The Rights You are Guaranteed
If You provide us with personal data on our websites or other channels, this is done on an entirely voluntary basis. If You choose not to provide the requested information, various customer benefits may not be available to You. In certain cases, only those who have submitted to us the required personal data are able to order products, use certain services and in other ways avail themselves of the activities and offers available on our website. We provide numerous options, depending on the exact circumstances, in order to help You retain control over Your data. These options may include displaying and editing Your data online. It may also be possible to unsubscribe from services or delete user accounts or to receive information about the data held.
You can access and amend Your personal data at any time by logging on to Your account on www.kopar.lt and entering Your account profile details. Click on “My Profile” or “My Account” to gain access to Your personal details.
If any of the information that You have provided us with has changed, e.g. if You change Your email address or other contact details, or if You wish to cancel Your registration with us, please let us know by editing Your details on the “My Profile” or ”My Account” pages or by sending an email outlining the changes to: firstname.lastname@example.org
In general, You have the following rights:
7.1. The right to request access to Your personal data
You are entitled to gain access to some of the personal data You provide to Kopar. You may request details of the information about You that we hold and process, including the purposes for which it is used, by sending an email to: email@example.com
You can also access Your personal details by logging on to Your Kopar account on www.kopar.lt and entering Your account profile details. Click on “My Profile” or “My Account” to gain access to Your personal details.
7.2. The right to amend and/or delete Your personal data
You have the right to request correction, appendage, deletion or blockage of Your stored personal data. To do so, send Your request by email to: firstname.lastname@example.org. Without undue delay of receipt of Your request, we will comply to the required extent. If, for any reason, we cannot comply with Your request, we will contact You.
7.3. The right to restrict the processing of Your personal data
In special circumstances, You have the right to restrict the processing of Your personal data. To request restriction, kindly contact us by sending an email to: email@example.com
7.4. The right to data portability
You have the right to receive Your personal data (concerning You only) in a structured, commonly used and machine-readable format (“data portability”), and have the right to transit this data to another data controller. To request data portability, kindly contact us by sending an email to: firstname.lastname@example.org
7.5. The right to object to the processing of Your personal data and to unsubscribe
|How do we define an inactive Newsletter sign up?||An inactive Newsletter Sign up is a person that has not opened and clicked an email for a period of up to 24 months. If a newsletter sign up, makes a purchase either instore or online or signs up to the Club, he/she is automatically transferred to the new status of a Purchaser, see below, and therefore follows the inactive definition of this new status.|
|What Personal data will be Erased if a Newsletter sign up is inactive?||All Personal data, such as: Name, email address and product preference will be erased. Full erasure.|
|When will Personal data be Erased?||Personal data will be erased, if the Newsletter Sign up has been inactive for up to 24 months.|
|What Personal data will be kept after the 3-year inactive period?||No Personal data will be kept unless required by local mandatory law.|
|How do we Erase Personal data?||IT will on a quarterly basis manually Erase Personal data. Personal Data will be erased in all IT systems.|
|Purchase – no account/guest check out||Someone who has made a purchase either online or offline without creating an account|
|How do we define an inactive customer?||An inactive customer is someone who have not engaged with us by: making a purchase either instore or online on a Kopar owned website while creating an account, logged into the account, opened and clicked an email for a time period of up to 5 years from the last engagement.|
|What Personal data will be Erased if a customer is inactive?||All Personal data, such as: name, email address, address, zip code, phone number, purchase. This means full erasure.|
|When will Personal data be Erased?||Personal data will be erased, if the customer has been inactive for up to five years.|
|What Personal data will be kept after the 5-year inactive period?||No Personal data will be kept unless required by local mandatory law.|
|How do we Erase Personal data?||IT will on a quarterly basis manually Erase Personal data. Personal Data will be erased in all IT systems.|
Emails sent to You by Kopar containing newsletter or marketing content include the option to unsubscribe by following the instructions set out in the email. If You do not wish to receive emails from us, You can simply click on the unsubscribe hyperlink and we will stop sending You emails.
For all other types of messages You may receive from us, such as maintenance announcements or administrational notifications, the receipt of such can only be terminated by deleting Your account. These messages are a mandatory part of user accounts and the related use of our website. Contact us by sending an email to: email@example.com should You be willing to delete Your account.
7.6. The right to withdraw Your consent at any time
You are at any time entitled to withdraw Your consent to our processing of Your personal data. The withdrawal of consent shall, however, not affect the lawfulness of processing based on consent before its withdrawal. Contact us by sending an email to: firstname.lastname@example.org to withdraw Your consent.
If You wish to withdraw Your consent to receiving promotional information and offers in general, including by postal services, email, text message, telephone or any other electronic means, You may do so at any time in writing to Kopar, or by sending a request via email to: email@example.com. Should we have misgivings regarding Your identity, we may ask You to provide identification.
7.7. Conditions and/or limitations on Your rights
There may be conditions to or limitations on Your aforementioned rights. We are therefore unable to guarantee Your right to data portability, as it is dependent on the specific circumstances of the processing activity.
8. Your Personal Information Retention Period
|Web visitors – IP address||Someone who has visited our website.|
|How do we define an inactive visitor?||An inactive visitor is someone who has not visited our website for 24 months.|
|What Personal data will be Erased if a customer is inactive?||All data that we have collected in regard to the visit on our website. Such as:
|When will Personal data be Erased?||Personal data will be erased 25 month after collected.|
|What Personal data will be kept after the 25-month inactive period?||No Personal data will be kept unless required by local mandatory law.|
|How do we Erase Personal data?||The data will automatically be erased after 25 months.|
Kopar will not retain Your personal data for longer than necessary for the purposes for which it is processed within the following processing activities:
9. The Security of Information and Data Integrity
We take the appropriate technical and organizational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized use, disclosure or access, in particular where processing involves the transmission of data over a network, and against all other unlawful forms of processing and misuse.
Kopar uses third party data processors to collect and process Your personal data. Any data processors commissioned by Kopar will only process Your personal data in accordance with Kopar’s instructions, and are legally obliged to adhere to strict security procedures when handling personal data.
9.1. Keeping information secure
Where we have provided You with, or where You have chosen, a password that enables You to access certain parts of our website, You are responsible for ensuring this password remains confidential. We ask You not to share Your password with anyone.
Unfortunately, transmission of information via the Internet is not wholly secure. Although we do our utmost to protect Your personal data, we cannot guarantee the security of Your data transmitted to our website; any transmission is done so at Your own risk. Once we have received Your information, we employ strict procedures and rigid security measures to try to prevent unauthorized access.
9.2. Social Networks
Our website provides You with social plug-ins from various social networks. If You choose to interact with a social network, Your activity on our website will also be made available to social networks such as Facebook and Instagram.
If You have logged in to one of these social network websites during Your visit to our website, the social network website may add this information to Your profile. If You are interacting with one of the social plug-ins, this information will be transferred to the social network website. If You do not want this data transfer, please log out of Your social network website before entering our website. We cannot prevent this data collection and social plug-in information transfer. Please read carefully the privacy policies of Your social networks for detailed information about their collection and transfer of personal data, Your rights, and how You can achieve satisfactory privacy settings.
Additionally, to improve Your user and brand experience, Your data may be passed to a third party (e.g. Facebook) for processing in accordance with data protection and privacy regulations.
9.3. Geolocation Services
Location-enabled services may be employed within some of our applications. Should You use these applications, they may receive information about Your actual location, such as GPS signals sent by a mobile device or information that can be used to approximate a location. You can enable or disable Your location services in Your device or browser settings.
10. Consequences of Non-disclosure of Personal Data
It is not possible to create a Kopar account or to make a purchase on the Kopar website if You are unable to provide us with the required information.
11. Contact Information
If You have any request concerning personal information processing or related issues, please write to us at: firstname.lastname@example.org
For any questions or notice, please contact us at: