Consent to the processing of personal data and rules of use of the site
Privacy Policy
Please read this Privacy Policy ("Policy") carefully to understand our principles for processing your Personal Data. This Policy applies to persons who interact with TM Xenia as consumers ("You"). This Policy explains how your Personal Data is collected, used and disclosed by KSENIJA ("KSENIJA", "We", "Us"). It also outlines how you can access and update your Personal Data that we hold and choose how we may use your Personal Data.
This Policy covers both our online and offline activities, including Personal Data, which we collect through a variety of channels, such as websites, applications, social networks, customer service, outlets, and various events. Please note that we may collect Personal Data from a variety of sources (websites, promotions and events). With this in mind, we combine Personal Data that was originally collected by different divisions of KSENIJA or partners of KSENIJA. Please see Section 9 of the Policy for more information on how you can object to this.
If you do not provide us with the necessary Personal Data (we will notify you when this happens, for example by indicating this information in the registration forms), we will not be able to provide you with our products and / or services for which they are required. This Policy may change from time to time (see Section 11).
This Policy contains important information on the following issues:
1. SOURCES OF PERSONAL DATA
2. WHAT YOUR PERSONAL DATA WE COLLECT AND HOW WE DO IT
3. PERSONAL DATA OF CHILDREN
4. COOKIES / SIMILAR TECHNOLOGIES, REGISTRATION FILES AND WEB LIGHTHOUSES
5. USE OF YOUR PERSONAL DATA
6. DISCLOSURE OF YOUR PERSONAL DATA
7. USE OF PERSONAL DATA
8. STORAGE AND / OR TRANSFER OF YOUR PERSONAL DATA
9. ACCESS TO YOUR PERSONAL DATA
10. CHOICE OF HOW WE USE AND DISCLOSE YOUR PERSONAL DATA
11. CHANGES IN OUR POLICY
12. OWNER (CONTROLLER) OF PERSONAL DATA
1. SOURCES OF PERSONAL DATA
This Policy applies to the Personal Data We receive from or about you using the methods described below (see Section 2), from the following sources:
KSENIJA websites. Consumer-oriented websites managed by KSENIJA, including sites we manage under our own domains / URLs and pages we run on social networks such as Facebook ("Websites").
Applications for smartphones KSENIJA. Consumer-oriented programs managed by KSENIJA, such as smartphone applications.
Email, text and other emails. Interaction between you and the company KSENIJA through electronic communication.
KSENIJA Customer Interaction Center (KSENIJA Care Line). Communication with our Consumer Interaction Center.
Registration forms. Electronic, paper or similar forms that we collect by mail, during events in stores, competitions and other promotions or events.
Interaction with our advertising. Interacting with our ads (for example, if you interact with one of our ads on a third-party website, we may receive information about such interactions).
The data we create. In the course of our interactions with you, we may create Personal Information about you (for example, information about your purchases on our websites).
Data from other sources. Social networks (eg Facebook, Google), marketing research (if feedback is not provided on an anonymous basis), third-party data aggregators, Ksenia's TM partners in public campaigns, public sources and data obtained from the acquisition of other companies.
2. WHAT YOUR PERSONAL DATA WE COLLECT AND HOW WE DO IT
Depending on the method of interaction with KSENIJA (online, offline, by phone, etc.), we collect from you different types of information, as described below.
Personal contact information. Includes any information you provide to us that will allow us to contact you, such as your name, mailing address, email address, social network details or telephone number.
Account login information. Any information you need to access your account. For example, email address, username, your password and / or checklist and answer.
Demographic information and interests. Any information that describes your demographic and behavioral characteristics. For example, your date of birth, age or age range, gender, geographical location, favorite products, hobbies and interests, as well as information about family or lifestyle.
Information from a computer / mobile device. Any information about a computer system or other technological device that you use to access one of our websites or applications, such as the IP address used to connect your computer or device to the Internet, the type of operating system, web browser type and version. If you access the KSENIJA website or application via a mobile device, such as a smartphone, the information collected will also include, where permitted, your unique device ID, advertising ID, geographic location, and other similar mobile device data.
Information on the use of websites. When navigating and interacting with our websites or newsletters, we use automatic data collection technologies to collect certain information about your activity. This includes information about which links you follow, which pages or content you view, and for how long, as well as other similar information and statistics about your actions, such as response time, download errors, and how long you visit certain pages. This information is captured through automated technologies such as cookies and web beacons, and collected through third parties for tracking for analytical and promotional purposes. You have the right to object to the use of such technologies, for more information see Section 4.
Market research and consumer feedback. Any information you voluntarily share with us about your experience of using our products and services.
Consumer content. Any content that you create and then share with us on social media or upload to one of our websites or applications, including the use of social networking applications such as Facebook. For example, photos, videos, personal stories, or other similar content. Where permitted, we collect and publish consumer content in connection with various events, including contests and other promotions.
Information from social networks. Any information that you share publicly on the social network, or information that is part of your profile on the social network (for example, on Facebook), and share which with us, you allow the social network. For example, the basic information of your account (this can be name, email address, gender, date of birth, city of residence, profile photo, user ID, friends list, etc.) and any other additional information that you allow to share a social network. We receive information from your profile (or part of the information) on the social network every time you interact with KSENIJA page on a social network such as Facebook, each time you use social network plugins, which is integrated into the website of KSENIJA (for example, Facebook Connect), or whenever you interact with us through social networks. To learn more about how KSENIJA receives your information from the social network, or to refuse to provide such information on the social network, please visit the website of the relevant social network.
Payments and financial information. Any information we need to fulfill your orders, or that you use to make a purchase, such as your debit or credit card information (holder's name, card number, expiration date, etc.) or other forms of payment if available). In any case, We or our payment service providers process payment and financial information in accordance with applicable laws, regulations and security standards.
Calls to the center of interaction with consumers ("Care line of KSENIJA"). Communication with the customer service center may be recorded or listened to in accordance with applicable law for operational purposes (for example, to ensure the quality of service or training). Payment card details are not recorded.
Sensitive Personal Data. We do not seek to process your sensitive Personal Data in the ordinary course of business. If for any reason it is necessary to process your sensitive personal data, we rely on your prior express consent to any processing that is voluntary (for example, for marketing purposes). If we process your sensitive personal data for other purposes, we rely on the following legal principles: (i) detection and prevention of crime (including fraud prevention); and (ii) compliance with applicable law.
3. PERSONAL DATA OF CHILDREN
We do not knowingly collect Personal Data from children under the age of 18. If we discover that we have inadvertently collected the Personal Data of a child under the age of 18, we will immediately remove the Personal Data of this child from our records. However, KSENIJA may collect Personal Data of children under the age of 18 directly from one of the parents or guardians, and with the express consent of this person.
4. COOKIE FILES / SIMILAR TECHNOLOGIES, REGISTRATION FILES AND WEB LIGHTHOUSES
Cookies / Similar technologies. Please review our Cookie Usage Policy for detailed information about the cookies we use, how you can manage your cookie settings, and to find out the purpose for which we use them.
Registration files. We collect information in the form of log files that record the activities of the website, and collect statistics on the pages you visit most often. These entries are created automatically and help us to debug, improve productivity and maintain the security of our websites.
Web beacons. Web beacons (also known as "web beetles") are small chains of code that are graphic images that are embedded in web pages or emails in order to send data back to us. Information collected through web beacons includes information such as IP address, as well as information on how you respond to the advertising message (for example, when the email was opened, what links you click in the email, etc.). We will use web beacons on our websites or include them in emails we send you. We use web beacons for a variety of purposes, including site traffic reporting, unique visitor counting, advertising, email verification and reporting, and personalization.
5. USE OF YOUR PERSONAL DATA
The following sections describe the different purposes for which we collect and use your Personal Data, as well as the different types of Personal Data that we collect for each purpose. Please keep in mind that not all of the following will apply to every consumer.
Why We use your personal data
Our reasons
Our legitimate interests
Customer service. We use your Personal Data to serve customers, including responses to your inquiries. This usually requires the use of certain personal contact information and information regarding the reasons for your request (eg order status, technical problem, product question / complaint, general questions, etc.).
· Fulfillment of contractual obligations
· Legal obligations
· Our legitimate interests
· Improvement and development of new products and services
· Greater efficiency
Contests, marketing messages and other promotions. With your consent (if applicable), we use your Personal Information to provide you with information about products or services (such as marketing messages, advertising campaigns or promotions) through emails, advertising messages, SMS, phone calls and mailing within the limits allowed by law. Some of our advertising campaigns and promotions are placed on third-party websites and / or social networks. Such use of your Personal Data is voluntary, which means that you may refuse to process your Personal Data for this purpose. For more information about how to change your marketing communications settings, see Sections 9 and 10 below. For more information about our contests and other promotions, please read the official rules and detailed information posted for each contest / promotion.
· Your consent (if required)
· Fulfillment of contractual obligations
· Our legitimate interests
· Identify our products and services that may interest you and inform you about them
· Defining consumer types for new products or services
Social Networks: We use your Personal Information when you use social networking features, such as the Like feature, to show you advertisements and interact with you on social media. You can learn more about how these features work, as well as what information about your profile we receive, and how you can opt out of such use of your Personal Data by reviewing the privacy policy on relevant social networks.
· Your consent (if required)
· Our legitimate interests
· Identify our products and services that may interest you and inform you about them
· Defining consumer types for new products or services
Personalization (offline and online). With your consent (if necessary), we use your Personal Data, (i) to analyze your preferences and habits, (ii) to anticipate your needs based on your profile analysis, (iii) to improve and personalize your experience interacting with our web. -sites and applications; (iv) ensure that the content of our websites / applications is optimized for you, your computer or other device; (v) to provide you with targeted advertising and content, and (vi) to allow you to use the interactive features of the Website as you wish. For example, we may store your username / email address so that you can log in quickly the next time you visit our site, or so that you can easily restore items you previously placed in your cart. Based on this information and with your consent (if necessary), we also show you certain content or promotions of KSENIJA that meet your interests. The use of your Personal Data is voluntary, which means that you may object to the processing of your Personal Data for this purpose. For detailed information on how to opt out of such use of your Personal Data, see section 10 below.
Execution of the order. We use your Personal Data to process and send your orders, inform you about the status of your orders, correct addresses and conduct identity checks and other measures to detect fraud. This involves the use of certain personal data and payment information.
· Fulfillment of contractual obligations
· With your consent (if necessary)
· Legal obligations
· Our legitimate interests
· Improvement and development of new products and services
· Greater efficiency
· Protect our systems, networks and personnel
· Compliance with legal obligations
Other general objectives (eg internal or market research, analytical data, security). In accordance with applicable law, we use your Personal Information for other commercial purposes, such as maintaining your account, conducting internal or marketing research, and evaluating the effectiveness of advertising campaigns. We reserve the right, if you have KSENIJA accounts, to synchronize these accounts into one shared account. We also use your Personal Data to manage and operate our communications, information technology and security systems.
Legal grounds or mergers / acquisitions. In the event that KSENIJA or its assets are acquired or merged with another company, including as a result of bankruptcy, we will transfer your Personal Data to any of our successors. We also disclose your Personal Data to third parties (s) if required by applicable law; (ii) for legal proceedings; (iii) in response to a request from a competent law enforcement authority; (iv) to protect our rights, privacy, property security or the public; or (v) to ensure compliance with the terms of any agreement or terms of use of our website.
· Legal obligations
· Our legitimate interests
· Compliance with legal obligations
· Protection of our assets and personnel
6. DISCLOSURE OF YOUR PERSONAL DATA
We provide your Personal Data to the following third parties:
Companies belonging to the KSENIJA group of companies (see Section 8).
Service providers. These are the companies we use to run our business (e.g., order fulfillment, payment processing, fraud detection and personal data verification, website operation, market research companies, support services, promotions, website development, data analysis , Customer Response Center (CRC), etc.). Service providers and their designated personnel are given access to and the ability to use your Personal Data on our behalf only to perform specific tasks assigned to them in accordance with our instructions, and they must ensure the confidentiality and protection of your Personal Data.
Credit Bureau / Debt Collection Agency. Within the limits permitted by applicable law, credit bureaus and debt collection agencies are external companies that we use, with which we can verify your creditworthiness if permitted by applicable law.
Third-party companies that use Personal Data for their own marketing purposes. Except as you have given your consent, We do not grant the right to use or sell Your Personal Data to third parties for their own marketing purposes. We will notify you of the details of such companies when we invite you to obtain your consent.
Third-party Data Recipients who use Personal Data lawfully or in connection with a merger / acquisition. We disclose your Personal Data to third parties if there are legal grounds for such disclosure or in connection with a merger / acquisition (see Section 5 for details).
7. USE OF YOUR PERSONAL DATA
In accordance with applicable law, we will use your Personal Data for as long as is necessary to achieve the purposes for which your Personal Data was collected (as described in Section 5 above) or to comply with applicable law.
8. STORAGE AND / OR TRANSFER OF YOUR PERSONAL DATA
We take appropriate measures (below) to ensure the confidentiality and secure storage of your Personal Data. Please note, however, that these safeguards do not apply to information you choose to make public by posting on social media.
Who can access your Personal Data. Your Personal Data will be processed by our authorized employees or authorized employees of the agencies depending on the specific purposes for which your Personal Data was collected (for example, our Consumer Protection Officers will have access to your consumer account).
Measures taken in the operating environment. We store your Personal Data in the operating environment using appropriate security measures to prevent unauthorized access. We adhere to high standards of personal data protection. Unfortunately, the transmission of information over the Internet is not completely secure, and although we will do our best to protect your Personal Data, we cannot guarantee the complete security of the data when transmitting through our websites / applications.
What we expect from you. It is important that you also contribute to the secure storage of your Personal Data. When registering for an account on the Internet, please make sure you choose a password that will be difficult for others to guess and never share it with anyone. You are responsible for the confidentiality of your password and any use of your account. If you use a public or third-party computer, never choose to remember your username / email address or password, and make sure you sign out of your account every time you leave your computer. You should also use the privacy settings we provide on our site / app.
Transfer of Your Personal Data. Due to the international nature of our business we may need to transfer your Personal Data between companies belonging to the KSENIJA group of companies and other third parties listed in Section 6 above, in connection with the objectives set out in this Privacy Policy. For this reason, we may transfer your Personal Data to other countries, which may have different laws and data protection requirements than the country in which you are located.
9. YOUR RIGHTS
Access to Personal Data. You may access your Personal Data and request a physical or electronic copy of all of your Personal Data held by us. You also have the right to receive information about the source of the collection of your Personal Data.
You can exercise these rights by sending us a request to the e-mail or postal address specified in Section 12, indicating your last name, first name and patronymic, place of residence (stay) and details of the identity document of the applicant, respectively to paragraph 1 of the fourth part of Article 16 of the Law of Ukraine "On Personal Data Protection". If the request is made by another person in your interest, without providing evidence that the request was lawfully made on your behalf, the request will be rejected. Please note that any information about you provided to us will only be processed in accordance with and within the limits permitted by applicable law.
Other rights (for example, change, destruction of Personal Data). if Your Personal Data in cases provided by law; (ii) make reservations regarding the restriction of the right to the processing of your Personal Data during the consent; and (iii) withdraw consent to any of the data processing operations.
Under current law, you also have the right to make a reasoned request to object to the processing of your Personal Data.
Please note that under certain circumstances we will not be able to delete your Personal Data without deleting your account. In some cases, we may continue to retain your Personal Data even after we receive your request for removal, in accordance with applicable law or in connection with the performance of the contract.
Please note that we require our registered users to verify their identity (e.g., login / email address, password) before they can access or make changes to their account. This helps prevent unauthorized access to your account.
We hope we can meet your expectations about how we process Personal Data. However, if you have unresolved issues, you also have the right to file a complaint with the competent authorities.
10. CHOICE OF HOW WE USE AND DISCLOSE YOUR PERSONAL DATA
We give you the opportunity to control what Personal Data you provide to Us through the following mechanisms:
Cookies / similar technologies. You control your consent through (i) the built-in program on the website or (ii) your browser so that you can opt out of all or some of the cookies / similar technologies, and we may notify you when they are used. See Section 4 above.
Marketing and promotions. You can consent to the use of your Personal Data by KSENIJA to promote your products or services by ticking the appropriate boxes in the registration forms, or by answering questions from our representatives of the Center for Consumer Interaction KSENIJA ("Care Line KSENIJA"). If you decide that you no longer wish to receive marketing communications from Us, you may opt out of receiving such communications at any time by following the instructions in each such notice. To unsubscribe from marketing messages sent in any way, including third-party social networks, you can at any time follow the link available in each of our messages, go to the website / application or to a third-party social network and set up your user preferences in your account, uncheck the appropriate boxes or call our Customer Service Center (KSENIJA Care Line).
Please note that even if you opt out of marketing communications, you will still receive administrative notifications from us, such as confirmation of orders or transactions, notifications of activity in your account (e.g., account verification, password change, etc.), and other important non-marketing messages.
Personalization (offline and online): if you want your Personal Data to be used by KSENIJA to provide you with an individual approach and to provide you with targeted advertising and content, you can indicate this by ticking the appropriate boxes in the registration form or answering the questions of our representatives of the Center for Consumer Interaction ("KSENIJA Care Line"). If you decide that you no longer want to get a personalized experience from KSENIJA, you can opt out at any time by going to the website / app and customizing your user preferences in your account by removing the appropriate flags or call our Consumer Interaction Center (KSENIJA Care Line).
Targeted advertising. We work with ad networks and other advertising service providers ("advertising providers") to provide advertising on our behalf and to other non-affiliated companies on the Internet. Some of these advertisements are tailored to your interests based on information collected on KSENIJA sites or non-KSENIJA sites related to a particular period. You can visit www.aboutads.info/choices to learn more about this type of advertising, as well as how to opt out of such advertising from companies participating in the Digital Advertising Alliance (" YES »). In addition, you can opt out of this type of mobile app advertising from companies participating in the DAA AppChoices by downloading the app from the iOS or Android app store. You can also stop collecting information about your location from your mobile device by changing your device's location settings.
11. CHANGES IN THIS POLICY
If we change the way you process your Personal Data, we will update this Policy. We reserve the right to make changes to our approaches to Data Processing and this Policy at any time, so we ask that you constantly review our Policy for any updates or changes.
12. OWNER (CONTROLLER) OF PERSONAL DATA
KSENIJA acts as the Owner (Controller) of your Personal Data.
If you have any questions or comments regarding our Policy or would like to file a complaint about our compliance with our personal data protection laws, please contact us.