PRIVACY POLICY FOR FREEPOLYGON
INTRO AND SUMMARY

Your privacy is important to freepolygon (“freepolygon” or “we”). In this policy, we want to inform you about how we process your personal data and about your rights. Personal data is any information that can be connected to you as a private person, for example name and contact information.

In short, this is why we process your data:

  • To the extent necessary for handling and delivering your order.
  • To give you offers and inspiration both by newsletters, text message and by targeted marketing in social media, and other media online and offline.
  • To communicate with you and answer your questions.
  • To ask you about freepolygon and your experience with us.
  • To remind you of an abandoned shopping cart and to provide our picture wall feature.
  • To create and maintain a customer account (incl. features such as favourites).
  • To comply with mandatory law (e.g. consumer and accounting law).

You have several rights according to data protection law. For example you always have a right to object against marketing.

Do you want to know more? Please read our detailed explanations below.

Below you can read more about how, why and for how long period we process your personal data.

WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?

Freepolygon is responsible for the processing of your personal data. Please note also that our payment provider(s) process personal data collected through our site upon purchase and are independently responsible for their processing.

If you want to contact us regarding our processing of your personal data, please contact us at contact@freepolygon.com.

WHO CAN GAIN ACCESS TO YOUR PERSONAL DATA?

Your personal information is processed primarily by us at freepolygon. We will never sell your personal data. In some cases, we share your personal data in order to fulfil our obligations to you in a good and efficient manner:

  • In order for us to ensure that you pay us, our payment provider(s) will gain access to your personal data.
  • In order for us to deliver your goods to your home address or to a postal agent, and to handle any returns, we will share your personal data with a carrier.
  • To collect and publish your reviews on our website we share your personal data with the supplier that provide the technical solution to collect and publish such reviews.
  • If a friend has referred you to us, we will share a hashed id (text-ID) of your email address with a supplier that have assisted us with enabling friend-referrals. The purpose is to know if we should pay the supplier of the service for referring a new customer or not. Note however that the supplier is not able to convert the text-ID to get access to your actual email address.
  • To market relevant products and to make our website as relevant as possible we share your personal data with those providing us with a marketing service including such as Google and Facebook.
  • We will share your personal data with IT suppliers that process the personal data on behalf of us as processors to assist us with IT-services. If you want more detailed information about who we share your personal data with, please feel free to contact us.
DO WE TRANSFER YOUR PERSONAL DATA OUTSIDE OF THE EU/EEA?

Freepolygon generally process your personal data within the EU/EEA, but in a few cases we use suppliers from countries outside of the EU/EEA. When transferring your personal data outside of the EU/EEA, freepolygon will ensure there is an adequate level of protection.

Freepolygon may transfer your personal data to the USA or UAE and our supplier that provides a service for sending newsletters and our suppliers that provides services for marketing relevant products and to make our website as relevant as possible.

Any US suppliers we may use have certification according to Privacy Shield. Privacy Shield is an agreement between the EU and the USA, which rationale is to protect the fundamental rights of Europeans and to ensure legal certainty for businesses transferring personal data to the USA. American companies are able to sign up to be Privacy Shield certified with the U.S. Department of Commerce. Such department will then verify that the suppliers’ privacy policies comply with high data protection standards.

If you have any questions about how we share your personal data or if you want the information appropriate safety measures we have, please contact us.

HOW CAN YOU AFFECT OUR PROCESSING OF YOUR PERSONAL DATA?

According to data protection legislation, you are entitled to a variety of rights to affect our processing of your personal data. Read more below.

RIGHT TO WITHDRAW CONSENT AND TO OBJECT TO PROCESSING

You have a right to, entirely or partly, withdraw a given consent for the processing of your personal data. Your withdrawal will have effect from the time of your withdrawal.

You have the right to object to our processing of your personal data. You always have a right to object to marketing from us, such as newsletters.

The right to object generally is applicable when the processing is based on a balance of legitimate interests. Read more about what this means in the tables below. In some cases however, the right to object does not exist (e.g. since we must store your personal data). If we can show compelling legitimate reasons for the processing that weigh heavier than your interests and fundamental rights or if it is for the purpose of determining, practicing or defending legal claims you never have a right to object to the processing.

RIGHT TO ACCESS

You have the right to obtain confirmation as to whether or not we are processing personal data concerning you. You can gain access to the personal data and obtain a copy of the personal data processed by us.

RIGHT TO RECTIFICATION

You have a right to obtain rectification of any inaccurate personal data concerning you and to ask us to have incomplete personal data completed.

RIGHT TO ERASURE (“THE RIGHT TO BE FORGOTTEN”) AND RESTRICTION OF PROCESSING

Under certain circumstances, you have a right to request erasure of your personal data. This is the case for example where the personal data is no longer necessary for the purposes for which they were collected or otherwise processed, or you withdraw your consent on which the processing is based and where there is no other legal ground for continuance of the processing.

You also have a right to request that freepolygon restrict its processing of your personal data. That is the case for example when the accuracy of the personal data is contested by you, or the processing is unlawful, and you oppose the erasure of the personal data and instead requests restriction of its use.

RIGHT TO LODGE A COMPLAINT TO A SUPERVISORY AUTHORITY

You always have the right to lodge a complaint with a supervisory authority.

You may do this in particular in the EU/EEA member state of your habitual residence, place of work or of an alleged infringement of the applicable data protection laws. In Cyprus, the supervisory authority is the National Data Protection Authority. This right is without prejudice to any other administrative or judicial remedy.

RIGHT TO DATA PORTABILITY

You have a right to ask us to transfer certain of your personal data we have about you to another company (data portability). This right applies to personal data that you have provided us in a structured commonly used, machine-readable and interoperable format if:

  • The processing is based on consent or on a contract; and
  • The processing is carried out by automated means.

In exercising your right to data portability, you have the right to have personal data transmitted directly from freepolygon to another controller, where technically feasible.

HOW AND WHY DO WE PROCESS YOUR PERSONAL DATA?

Our aim is to be as transparent as possible regarding how and why we process your personal data. In the table you can read more detailed information about why we process your personal data (the purposes of processing), what personal data we process, our legal basis for processing your personal data, and how long we process your personal data for each purpose.

We process personal data that you have chosen to share with us.

COOKIES

HOW HAVE WE ASSESSED THE BALANCING OF INTERESTS WHEN THE LEGAL BASIS FOR PROCESSING OF YOUR PERSONAL DATA IS OUR LEGITIMATE INTEREST?

For some purposes, freepolygon processes your personal data relying on our legitimate interest as legal basis for the processing. When assessing the legal basis we rely on a balance of interests test, through which we have determined that our legitimate interest for the processing outweighs your interest and your fundamental right not to have your personal data processed. We have stated what our legitimate interest is in the tables above. You are welcome to contact us if you want to read more about how we have done this test. Our contact details are as stated in the beginning of this privacy policy.

This privacy policy was adopted by freepolygon on 12 December 2020.

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