At SewToy we are aware of the importance of the right to privacy and fully respect it. Therefore, we treat the personal data of data subjects with due care and responsibility, respecting the provisions of the European General Data Protection Regulation (GDPR) and the Personal Data Protection Act (ZVOP-1) when processing personal data. Questions regarding data processing can be sent to me via webpage contact form.
SewToy ensures that the personal data of customers, users of sewtoy.com, and all other information collected during the process of visiting the Website or making an online purchase is protected from disclosure and transmission to unauthorized third parties. All personal data of customers and users are confidential. Only me and authorized subcontractors can access your personal data, all-access being limited solely to the extent and purpose necessary for the smooth running of the work and sales processes and marketing purposes, subject to consent.
2. THE DATA CONTROLLER
For purposes of EU data protection law, I, Maja Lapajne, am the data controller of your personal information. If you have any questions or concerns, you may contact me via webpage contact form.
We process your personal data in accordance with the General Data Protection Regulation (GDPR), the Personal Data Protection Act (ZVOP-1), and other regulations governing personal data protection. SewToy, as the Data Controller, processes certain personal data only based on your prior consent. In some cases, the processing of some personal data is necessary for the implementation of a contract, the fulfillment of legal obligations, or the legitimate interest of the Data Controller. This means that the legal basis for the processing of your personal data may be:
- IMPLEMENTATION OF A CONTRACT
If you make an online purchase with us, the submission of your information is a contractual obligation. In this case, the data will only be processed for the purpose of fulfilling the rights and obligations arising from the contract (e.g. e-mail for delivery of digital products, contacting customers for purchase, payment method, etc.).
2. FULFILMENT OF STATUTORY OBLIGATIONS
In certain cases, the processing of your personal data is an obligation imposed by law (for example, tax regulations on the storage of invoices).
We may process some of your personal data based on the legitimate interest of the Controller, SewToy, namely when our interests exceptionally outweigh your fundamental rights and freedoms. On a legitimate interest basis, we, therefore, process your personal data for the purpose of maintaining the Website technically, protecting, and ensuring the security of the information system and confidential information. Our legitimate interest in the processing of personal data is also the processing of data in order to prevent fraud and other crimes, to resolve potential disputes and complaints, and to safeguard legal claims.
Data that are processed on a legitimate interest basis are processed to the minimum extent necessary for that purpose.
The basis for obtaining and processing your personal data is consent. Thus, based on your consent, we process your personal data for direct marketing purposes, and you may revoke that consent at any time. SewToy processes personal data on the basis of consent for the processing of personal data that an individual submits to the Company for the following purposes:
- for direct marketing purposes—to receive notifications. Notifications contain current offers, benefits and/or invitations to the events of the Controller, as well as useful tips on eye care and good eyesight;
- to perform marketing analysis and customer segmentation, and deliver customised product and service offers.
Depending on the personal information you provide, you can receive notifications and personalized offers by email at the email address provided.
You may withdraw or change your consent at any time in the same manner as the consent was given; by clicking on the ‘unsubscribe’ button located at the bottom of the email.
4. THE DATA CONTROLLER
Following the principle of proportionality, we only collect data about you that are necessary to achieve the purpose pursued by the processing. For what cases we process your personal data, what data, and for what purposes, please read below.
WHEN VISITING THE WEBSITE
WHEN MAKING AN ONLINE PURCHASE
When making an online purchase, the following personal data are processed for the purposes of placing the order: first and last name, email address, item purchased and amount, delivery method, and payment method.
The provision of data is a contractual obligation and the data are processed for the purpose of processing your order: completion and confirmation of the order, preparation of the product, delivery of the product, resolution of complaints and other purchase-related communication. If you do not provide the data, we cannot fulfil the obligations arising from the order.
Some of the personal data you provide when making an online purchase may also be accessed by third parties for the purpose of supporting, analysing and continuously improving our services, processing payments or delivering orders. These third parties have access only to such personal data as is strictly necessary for them to provide the services they provide to us and only for the purposes of performing these tasks on our behalf and may not use them for any other purpose. In any case, contractors are obliged to protect your personal data.
WHEN FILING A COMPLAINT
In the event that you file a complaint regarding a purchased item, we process the following data: first and last name, e-mail, the reason for complaint. We need and process the personal data provided solely for the purpose of resolving the complaint and communicating with you.
WHEN SUBSCRIBING TO THE NEWSLETTER
By subscribing to the newsletter, you agree to be sent news of special benefits and novelties, and for this purpose, we process your email address information. You can withdraw your consent to this processing at any time by clicking the unsubscribe link available at each newsletter.
5. PROTECTION OF PERSONAL DATA
We collect your personal data to the minimum extent possible. This is why we allow you to make purchases without registering and without collecting unnecessary personal data (i.e., data not required to implement the contract).
We respect your privacy. We don’t exaggerate with newsletters.
The user is also responsible for data protection by properly ensuring the security of their mobile device or computer, as well as protecting the user name, password and using appropriate software (antivirus) protection of the electronic device used for accessing our Website. In order to ensure that these measures are effective in preventing unauthorised access to your personal data, you should be aware of the security features available to you through your browser.
The Controller endeavours to protect your personal data appropriately, but we do not guarantee complete protection of the personal data you provide to us and are not responsible for theft, destruction, loss, intentional or unintentional disclosure of your personal data or information about you. SewToy adheres to generally accepted standards for protecting received data both during and after transmission, but no electronic transmission or storage method is 100% secure, so full protection cannot be guaranteed.
6. STORAGE PERIODS
We store personal data for as long as is necessary to provide our services or for as long as there are legal obligations to do so.
Information related to the payment for the purchase in the Online Store and related contact details of data subjects for the purpose of fulfilling the contractual obligations is kept until full payment of services or until the expiry of the limitation period in respect of an individual claim, which may be up to five years by law. In accordance with tax regulations, issued invoices are kept for 10 years after the end of the year in which the invoice was issued.
We store your personal data for as long as necessary to fulfil the purpose for which the data are processed. After this time, your data are deleted, destroyed, blocked or anonymised.
In certain cases, data storage periods are set by law, so data are stored for as long as is necessary to fulfil legal obligations
7. TRANSFER OF DATA TO THIRD COUNTRIES
SewToy does not transfer the collected personal data to third countries unless we collect your e-mail and consent for newsletters via Sumo online platform and send you emails via the MailChimp online platform. This online platform stores personal data for sending messages designed to facilitate the fulfillment of the contract (name, email, country) and sending notices of special offers and news to individuals (name, email, country).
8. RIGHTS RELATING TO THE PROCESSING OF PERSONAL DATA
SewToy ensures the exercise of the rights of data subjects. The data subject’s claims regarding the exercise of their rights may be sent via webpage contact form.
Data subjects have the following rights regarding personal data:
- RIGHT OF ACCESS TO DATA
As a data subject, you can at any time request that SewToy informs you whether the data relating to you are being processed and, if so, provide access to personal data and information regarding the processing of your personal data (e.g., the purpose of the processing, the type of personal data, the recipient to whom personal data was or will be transmitted, estimated data storage period, technical and organisational data protection measures, etc.).
- RIGHT TO RECTIFICATION
Individuals may at any time request that SewToy make it possible for inaccurate personal information concerning you to be rectified and supplement incomplete personal information.
- RIGHT TO ERASURE
This means that this right is not absolute—some of your personal data (such as identification and contact information, order information) will not be (immediately) deleted as we are required to retain them for the fulfilment of our legal obligations (e.g. for tax purposes, etc.) or retain them to enforce, implement or defend our legal claims. We will make an assessment of whether all requested personal data will be completely erased, on a case-by-case basis, since the Controller is obliged to carefully check that there is no valid legal basis or other overriding reason for the retention of data.
- RIGHT TO RESTRICTION OF PROCESSING
Subject to the terms and conditions set out in the applicable regulations, as a data subject, you may at any time request that SewToy grants the right to restrict the processing of your personal data as required by GDPR.
- RIGHT TO DATA PORTABILITY
The data subject may at any time request that SewToy enables the transfer of personal data in a structured, commonly used, and machine-readable form to the data subject.
- RIGHT TO OBJECT
In the event that SewToy processes personal data on a legitimate interest basis, as presented above, the data subjects may object to such processing in certain cases. SewToy will cease processing such personal data unless it determines that it has reasonable and legitimate reasons for continuing to process them or if the processing is necessary for legal reasons.
- WITHDRAWAL OF CONSENT
As a data subject, you may withdraw your consent at any time in cases where consent is given for a specific purpose of processing your personal data.
Withdrawal of consent shall not affect the lawfulness of the processing of personal data which took place before its withdrawal.
RIGHT TO FILE A COMPLAINT WITH THE SUPERVISORY AUTHORITY
Data subjects have right to file a complaint with the Information Commissioner of the Republic of Slovenia, insofar as they believe that their personal data are being processed contrary to the applicable regulations governing the protection of personal data. The complaint procedure with the supervisory authority is published on the supervisory authority’s website.
9. OTHER RECIPIENTS OF PERSONAL DATA
In certain cases and solely based on an appropriate legal basis, your data may also be disclosed to third parties. We share your personal data with our trusted business partners. They are not authorized to access your personal data for their own purposes but only store it or use it for the needs of the sewtoy.com Online Store (e.g. to successfully complete a credit card payment transaction, etc.).
In case of credit card payment, we share personal data for business purposes and personal data for security purposes (the credit card number is stored in an anonymous form after payment is made, we do not keep your password):
with the contract partners for the provision of payment services Paypal (https://www.paypal.com/) and Stripe (https://stripe.com/).
If you subscribe to our newsletter, we may share your personal data (email address, first and last name and consent to use your email address to send our e-newsletter) solely for the purpose of sending e-newsletters with the MailChimp online platform (https://mailchimp.com) and Sumo online platform (https://sumo.com/).
You can unsubscribe from our newsletters at any time in any promotional email by clicking on the email unsubscribe link.
Using social media plugins: We do not use social media plugins. The Facebook, Pintares and Instagram symbols and logos on our site are solely links to the pages of these services. If you click on one of these symbols, the service provider will not receive any of your personal data from us. There you can share and display the content of sewtoy.com. By using the services of each provider, you agree to their data protection provisions.
In cases as may be prescribed by law, your personal data may be disclosed to the public authorities, as necessary for the fulfilment of our legal obligations or for the performance of their official duties, such as the police, the court, the tax authorities and others.
To achieve the above purposes of data processing, your data may also be disclosed to other contractors who process your personal data on our behalf and under our instructions. These are
- data processing and analytics providers;
- IT systems maintenance staff;
- providers of emailing and marketing automation tools;
- providers of customer relationship management systems;
- online advertising solution providers;
- law firms and other legal counsel providers.
Contractual processors will not use your personal data for their own purposes or transfer them to third parties without our consent. At the same time, we ensure that our contract processors are trusted, business partners.
10. SOURCES OF PERSONAL DATA
In most cases, the data we process about you is provided by you (for example, by browsing the Website and related cookies, placing an order, subscribing to the newsletter). If you choose a card payment method in the Online Store, our payment system providers will provide us with information about whether the transaction was successfully completed without disclosing your bank account number to us.
11. FINAL PROVISIONS
Anything not specifically regulated in this document is subject to applicable law.
SewToy reserves the right to amend this document. We will notify you of the change in an appropriate manner, i.e. by posting it on sewtoy.com 30 days before the changes take effect.
If you have any questions or concerns about the specific provisions of this Policy, please email me via the webpage contact form.