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User Privacy Policy

Maintaining the security of User data is a priority at Karuselle, and we are committed to respecting User privacy as well as personal data related rights. Karuselle believes that it is important for the Users to know, how we treat the information about them that we receive in connection with their use of the Website.
This Privacy Policy sets out what information Karuselle collects, how and from which sources it is collected, what Karuselle is doing with the information collected and how this information is protected, secured.  By using our services and/or creating an account on the Website, you are accepting and consenting to the provisions described in this Privacy Policy as well as the General Terms and Conditions (hereinafter – “Terms and Conditions”).
All User personal data is collected and processed in accordance with Lithuanian and EU data protection laws.
Capitalized terms that are not defined in this Privacy Policy have the meaning given them in our Terms and Conditions.


1. COLLECTION AND USE OF PERSONAL DATA


1.1 The controller, data processors and the scope of application 
Any personal information provided to or gathered by the Website is controlled by UAB “Karuselle”, registered at Sakalu str. 6-40, LT-08124 Vilnius, Republic of Lithuania.
This Privacy Policy applies to any Karuselle site where this Privacy Policy appears, and to any Karuselle application, service, or tool where this Privacy Policy is referenced, regardless of how the Users access or use them, including through mobile devices. 
The Privacy Policy does not apply in cases where personal information is collected by third parties that may interact with our Website, and does not apply to personal information collected at any other website or offline by Karuselle (unless specifically stated otherwise).
Karuselle may engage third parties for processing of personal data of the Users and transfer their data to other legal entities, as further described in this Policy. 
Specifically, all information relating the Buyer’s Order shall be subject to automatic data processing by [korteles aptarnaujanti įmonė]. The purpose of this automatic data processing is to avoid credit card fraud. 


1.2 Information collected
Karuselle collects and processes the following information: 
•    User’s first and last name, year of birth and gender;
•    contact details: full postal address including billing and delivery addresses, mobile telephone numbers and e-mail address;
•    photographs uploaded by the User;
•    history of purchases, orders, transactions and Product listings;
•    User IP address, also connection data and location data when the User authorizes it;
•    User login information and passwords;
•    payment card or bank details;
•    correspondence and communications with Karuselle, history of claims and incidents;
•    other publicly available personal data shared by the User on the Website.
This list is not exhaustive and, in specific instances, Karuselle may need to collect additional data for the purposes set out in this Privacy Policy. Some of the above personal data is collected directly, for example, when Users set up an account on the Website or contact our customer support service. Other personal data is collected indirectly, for example, Users’ connection data or traffic data. We may also collect personal data from third parties who have your consent or authorization to pass your details to us, or from publicly available sources.
The Website and Karuselle services in general are not intended for persons under the age of 18. Karuselle does not knowingly collect personal information from users, who are under the age of 18.
All Users are informed which information must be provided to Karuselle for it to be able to provide services (usually there is a star near the field upon the provision of data). Other information is optional and may be provided on voluntary basis to increase the quality of our services.
Karuselle will not retain User data for longer than necessary for the purposes set out in this Privacy Policy. Data shall be stored until:
•    the User stops using our services and deactivates his/her account; or
•    2 years after the last activity on User account; or
•    data is no longer necessary and relevant for our operations.


1.3 The legal basis for processing data
Karuselle collects and uses Users’ personal data because it is necessary for:
•    the pursuit of our legitimate interests (e.g. supplying Products to Users, managing the Website, exercising other duties of Karuselle in the capacity of the agent, etc.);
•    complying with our duties and exercising our rights under a contract with the User; or
•    complying with our legal obligations, as laid down by applicable legal acts.

User’s consent as a legal basis for processing is used in relation to direct marketing or third-party access to his/her information. Users have the right to withdraw their consent at any time at no cost. Where consent is the only legal basis for processing, Karuselle will cease to process data (although it will have the right to further store it to the extent necessary under applicable legal acts) after the consent is withdrawn.


1.4 The use of personal information
The main purpose of processing User data is to offer Users an optimal, efficient and personalized experience on the Website. Karuselle uses your personal data: 
•    to provide services or process transactions that you have requested or agreed to receive;
•    to solve any problems and disputes regarding the use of the Website;
•    to personalize, value, improve our services and content;
•    to inform Users about our services and those of our partners, by means of targeted marketing and/or promotional offers, with User consent;
•    to prevent, detect and enquire about all illegal activities under applicable law;
•    to ensure that all Karuselle policies are thoroughly applied;
•    to comply with our legal and regulatory obligations;
•    to contact and inform you regarding the use of the Website and/or changes to the Website and/or Website’s policies;
•    for internal Karuselle business purposes;
•    for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.


2. DATA COLLECTION AND USE BY THIRD PARTIES 


2.1 Sharing data with third parties
Personal information collected on the Website is intended for Karuselle’s use as described in Section 1.4 of this Privacy Policy. 
To make certain services available to you, Karuselle may need to share your personal data with some of our service partners. These include IT, delivery and marketing service providers, couriers, etc. However, it should be noted that mentioned service providers can only use your data to provide services to Karuselle and to you, and for no other purposes.
Aside from our service providers, Karuselle will not disclose your personal data to any third party, except as set out below. Karuselle will not share, sell or rent User data to other organisations for marketing purposes, unless you have given your prior consent for that. Karuselle may share anonymous data, such as aggregated User statistics, with third parties without your consent.


2.1.1 Data transfer upon User agreement 
Users may be presented with an opportunity to receive information and/or marketing offers directly from third parties. If Users agree to share their personal information with such third parties, the personal information will be disclosed and it will be subject to privacy policies and practices of such third parties. Karuselle cannot guarantee the privacy or security of your information once you provide it to a third party and we encourage you to evaluate the privacy and security policies of mentioned third party before entering into a transaction and choosing to share your information. In case Users later retrieve their consent to share their personal information with the mentioned third party, Users shall contact and inform that third party about the decision directly.


2.1.2 Third-Party Services
Karuselle may use third-party service providers for various services, such as hosting the Website, designing and/or operating the Website’s features, tracking activities on the Website and providing analytics, also services that enable us to send special offers to Users or other administrative services. To be able to ensure the provision of mentioned services, Karuselle may provide such service providers with access to User information, including device identifiers and/or personal information. 
While Karuselle may use third-party analytics services to evaluate and provide us with information about the use of the Website, Karuselle does not share User personal information with such analytics service providers. However, they may set and access their own tracking technologies on your device and may collect or have access to information about you.


2.1.3 Legal compliance 
Karuselle may share your data with governmental bodies, regulators, law enforcement agencies, courts and insurers where we are required to do so:
•    to comply with our legal obligations under applicable law; 
•    to protect the Website according to the Terms and Conditions or other applicable policies, including investigation of potential violations thereof, and to exercise our legal rights; 
•    to protect the safety, rights, property or security of the Website, any User or third party; 
•    to detect, prevent or otherwise address fraud, security or technical issues. 
Karuselle may also use IP addresses or other device identifiers, to identify Users that infringe or might infringe any obligation under applicable law or Terms and Conditions. To do so, Karuselle may cooperate with third parties, such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, and may disclose such information to third parties, subject to applicable law. Such disclosures may be carried out with or without any notice to Users.


2.1.4 Business transfers
As we continue to develop our business, we might create, sell or buy stores, subsidiaries or business units. In such transactions, User information generally is one of the transferred business assets, which remains subject to the promises made in any pre-existing Privacy Policies (unless, of course, the User consents otherwise). 
Karuselle may share User information, including device identifiers and/or personal information with its parent company, subsidiaries and affiliates. Karuselle also reserves the right to disclose and transfer all such information to a subsequent owner, co-owner or operator of the Website or applicable database.


2.2 Additional Website functions
In cases where the User account on the Website is connected or linked to his/her accounts on third-party websites, such third parties provide the Website with User information (for example, when the User chooses to log-in on the Website via his/her Facebook account). All information received by Karuselle in above mentioned manner will be processed under the terms and conditions of this Privacy Policy. 
To facilitate communication between websites, Karuselle may provide the application programming interface (API) of third-party websites or external links on the Website. For example, such means may be implemented to enable Users to send emails, tweets or posts by other social media directly from the Website. Such third parties may retain User information provided during such communication. Karuselle cannot control or have access to your information processed through the means of third-party communication. You should review the third party’s terms of use and privacy policies before engaging in their use. We encourage you to evaluate the privacy and security policies of mentioned third partiers before engaging in use of their products.


2.3 Third-party advertising
Third-party advertisers or advertising companies working on their behalf sometimes use technology to serve the advertisements that appear on the Website. They automatically receive your IP address when this happens. They may also use cookies to measure the effectiveness of their advertisements and to personalize advertising content. Karuselle does not have access to or control over cookies or other features that advertisers and third-party sites may use, and the information practices of these advertisers and third-party websites are not covered by this Privacy Policy.
Technologies used by third-party advertisers may be set on the Website, among other things: 
•    to help deliver advertisements to you that you might be interested in; 
•    to prevent you from seeing the same advertisement too many times; and 
•    to understand the impact of the advertisement that has been delivered to you. 

Users acknowledge and agree that mentioned technology may access and may impact User’s device.


3. USER RIGHTS


Users are entitled to certain rights regarding the protection of their data. Those rights are:
•    the right to access information we have collected about you;
•    the right to rectify incorrect / inaccurate information about you;
•    the right to transfer all or part of the information collected about you to you or another data controller, where technically feasible (the right to data portability);
•    the right to erase any data concerning you. Users may demand erasure of data without undue delay for legitimate reasons, e.g. where data is no longer necessary for the purposes it was collected, or where the data has been unlawfully processed;
•    the right to restriction of data processing. Users, for legitimate purposes, may obtain restriction of data processing from the controller;
•    the right to object to processing of personal data when processing is carried out on the basis of legitimate interest (i.e., for our business purposes specified in Section 1.3 hereof).
To exercise any of the rights mentioned above, please contact us at email: customercare@karuselle.com., phone: +370 636 01 007.
Please note that in case Karuselle has reasonable doubts about the identity of the User that contacted us regarding the above-mentioned rights, we shall request further information to confirm your identity.
Users have the right to lodge a complaint to the national Data Protection Agency in their country of residence in an event where their rights may have been infringed. However, we recommend attempting to reach a peaceful resolution of possible dispute by contacting us first.


4. SECURITY


Karuselle protects User information using reasonable technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration.  Karuselle stores the collected User information at UAB „Karuselle“, company code 304497677, home address Sakalu str. 6-40, LT-08124 Vilnius, Lithuania. If you believe your account has been abused, please contact us at email: customercare@karuselle.com, phone: +370 636 01 007.
In addition, Karuselle recommends that Users take at least the following security measures to enhance their online safety:
•    keep account login information and passwords private;
•    when creating a password, use at least 8 characters; 
•    avoid using the same password for multiple online accounts;
•    update their software and install the latest security patches.


5. GENERAL PROVISIONS


Karuselle may amend the Privacy Policy from time to time. Karuselle shall notify the Users when changes are made by making a revised version available on the Website and shall indicate the date that revisions were last made. 
Users understand and agree that their continued access to or use of the Website after any posted modifications to the Privacy Policy indicates an acceptance and agreement to such modification. 
In case any provision of the Privacy Policy is held to be invalid, void or for any reason unenforceable, such provision shall not affect the validity and enforceability of the remaining provisions. 
The Privacy Policy is applicable from the date of its publication on the Website.