Privacy and Cookies policy
Updated on 24th May 10, 2018
At Krakowsky, we’re working hard to serve shoppers a little better every day. Looking after the personal data you share with us is a hugely important part of this. We want you to be confident that your data is safe and secure with us, and understand how we use it to offer you a better and more personalised shopping experience.
What this policy covers
The data controller of your personal data is jest Kinly Management Ltd, Cardiff, 94 Mackintosh Place, CF24 4RR, United Kingdom, company registration number 09365726 (referred to in this policy as “we”, “us” or “Krakowsky”).
We are committed to doing the right thing when it comes to how we collect, use and protect your personal data. That’s why we’ve developed this privacy and cookies policy (“Policy”), which:
We offer a wide range of products and services, so we want you to be clear about what this Policy covers. This Policy applies to you if you use our services (referred to in this Policy as “our Services”). Using our Services means:
We process your personal data in accordance with the EU (2016/679) General Data Protection Regulation (“GDPR”) as well as with other applicable data protection regulations that supplements and/or implements GDPR.
Personal data we collect
This section tells you what personal data we may collect from you when you use our Services and what other personal data we may receive from other sources.
When you register for our Services, you may provide us with:
· Your personal details, including your postal and billing addresses, email addresses, phone numbers and date of birth and title
· Information relating to your membership of any of our schemes,
· Your account login details, such as your username and the password that you have chosen
When you shop with us by using browse our Websites or use our Mobile Apps, we may collect:
· Information about your online purchases (for example, what you have bought, when and where you bought it and how you paid for it)
· Information about your online browsing behaviour on our Websites and Mobile Apps and information about when you click on one of our adverts (including those shown on other organisations’ websites)
· Information about any devices you have used to access our Services (including the make, model and operating system, IP address, browser type and mobile device identifiers, date and time of your access to our Services, address of website you were re-directed from to our website, other data transmitted through standard HTTP(s) request headers, data used to maintain online session after logging in)
When you use vouchers or coupons, we may collect:
· Transaction information, including online purchases.
When you contact us or we contact you or you take part in promotions, competitions, surveys or reviews about our Services, we may collect:
· Personal data you provide about yourself anytime you contact us about our Services (for example, your name, username and contact details, your membership number), including by phone, email or post or when you speak with us through social media
· Details of the emails and other digital communications we send to you that you open, including any links in them that you click on (for example those that enable us to know whether and when you opened that communication).
· Your feedback and contributions to customer surveys or reviews
Other sources of personal data
We may also use personal data from other sources, such as specialist companies that supply information or online media channels. For example, this other personal data helps us to improve and measure the effectiveness of our marketing communications, including online advertising.
How and why we use personal data
This section explains in detail how and why we use personal data.
We use personal data to
This means that processing your personal data allows us to
Why do we process your personal data in this way?
Make our Services available to you
Manage the accounts you hold with us,
Process your orders and refunds
We need to process your personal data so that we can manage your customer accounts, provide you with the goods and services you want to buy and help you with any orders and refunds you may ask for.
We also need to process your personal data so that we can provide you with vouchers and/or coupons you earned while being our loyal customer.
At the time we collect the data:
-purchase & transactions data
We will not be able to provide you with your products or services if you do not provide us with this information.
-following fulfilment of your order and for the other personal data set out in this section
Manage and improve our day-to-day operations
Manage and improve our Websites and Mobile App
Some cookies are necessary so you should not disable these if you want to be able to use all the features of our Websites and Mobile Apps. You can disable other cookies but this may affect your customer experience. For more information about cookies and how you can disable them, see the cookies and similar technologies section
Help to develop and improve our product range, services, stores, information technology systems, know-how and the way we communicate with you
We rely on the use of personal data to carry out market research and internal research and development, and to improve our information technology systems (including security) and our product range, services and stores. This allows us to serve you better as a customer.
Detect and prevent fraud or other crime
It is important for us to monitor how our Services are used to detect and prevent fraud, other crimes and the misuse of services. This helps us to make sure that you can safely use our Services in line with applicable terms and conditions.
Personalise your Krakowsky experience
Use your online browsing behaviour and online purchases to help us better understand you as a customer and provide you with personalised offers and services.
Looking at your browsing behaviour and purchases allows us to personalise our offers and services for you. This helps us meet your needs as a customer.
Provide you with relevant marketing communications (including by email, SMS, post or online advertising), relating to our products and Services. As part of this, online advertising may be displayed on our websites and on other organisations’ websites and online media channels(including for example through Google AdWords). We may also measure the effectiveness of our marketing communications and those of our suppliers.
We want to ensure that we provide you with marketing communications, including online advertising, that are relevant to your interests. To achieve this we also measure your responses to marketing communications relating to products and services we offer, which also means we can offer you products and services that better meet your needs as a customer.
For most marketing communications we send to you via e-mail or SMS we rely on your consent, however there are situations in which it is in our legitimate interests to use your personal data in this way.
Contact and interact with you
Contact you about our Services, for example by phone, email or post or by responding to social media posts that you have directed at us.
We want to serve you better as a customer so we use personal data to provide clarification or assistance in response to your communications as well as to inform you about the changes we made or are going to make to our Services that affects you (such as changes to this Policy or to the terms & conditions of our Services).
Manage promotions and competitions you take part in, including those we run with our suppliers.
We need to process your personal data so that we can manage the promotions and competitions you choose to enter.
Invite you to take part in and manage customer surveys, reviews and other market research activities carried out by Krakowsky and by other organisations on our behalf.
We carry out market research to improve our Services. However, if we contact you about this, you do not have to take part in the activities. If you tell us that you do not want us to contact you for market research, we will respect this choice. This will not affect your ability to use our Services.
Legitimate Interests, however when we want to invite you via electronic means such as e-mail or SMS we will rely on your consent.
Disputes, complaints or claims
In order to resolve complaints, legal claims or disputes involving you or us.
For example if you are not satisfied with the products you bought from us or you have any accident or there is an incident at our stores. In some cases this could include medical reports.
Establishing, Exercising or Defending Legal Claims, however in some cases we rely also on our Legitimate Interests or on a Specific Law Provision that enable us to process your data in order to comply with our legal obligation.
To help us to better understand you as a customer and to be able to provide you with services and marketing communications, including online advertising, that are relevant to your interests we also combine personal data we collect when you make purchases with personal data collected from our Websites or Mobile Apps.
Our Legitimate Interests in using your personal data
Where we have mentioned above our use of your personal data is based on our “legitimate interests”, these are:
Sharing personal data with Krakowsky Partners, suppliers and Service Providers
This section explains how and why we share personal data with Krakowsky Partners, suppliers and Service Providers.
When we share personal data with these companies we require them to keep it safe, and they must not use your personal data for their own marketing purposes, unless you separately gave them your consent for it.
We work with carefully selected Service Providers that carry out certain functions on our behalf. These include, for example companies that provide us with:
· technology services (for example support our Websites, Mobile Apps and other business systems we use to provide you with our Services) - PrestaShop
· processing of payments – PayPal UK,
· delivery services – DPD Poland
· direct marketing companies who send electronic communication, including Krakowsky newsletters, on our behalf (for example Mailchimp, Google)
- Social Media (Facebook)
- Livechat (Zopim Zendesk)
We only share personal data that enable our Service Providers to provide their services.
Sharing personal data with other organisations
This section explains how and why we share personal data with other organisations.
We may share personal data with other organisations in the following circumstances:
How we protect personal data
We know how important it is to protect and manage your personal data. This section sets out some of the measures we have in place.
We use computer safeguards such as firewalls and data encryption, and we enforce physical access controls to our buildings and files to keep this data safe. We only authorise access to employees who need it to carry out their job responsibilities.
However, whilst we take appropriate technical and organisational measures to safeguard your personal data, please note that we cannot guarantee the security of any personal data that you transfer over the internet to us.
For more information about transferring data outside the EEA, including for a copy of Model Clauses, please visit: https://ec.europa.eu/info/law/law-topic/data-protection_pl
How long we use personal data for
We will not keep your personal data longer than we need to, how long this is depends on several factors, including:
Marketing and market research
This section explains the choices you have when it comes to receiving marketing communications and taking part in market research.
We will send you relevant offers and news about our products and services in a number of ways including by email, but only if you have previously agreed to receive these marketing communications. When you register with us we will ask if you would like to receive marketing communications, and you can change your marketing choices at anytime online, over the phone or by clicking the ‘unsubscribe’ link in any email communication that we send you. We will then stop sending any further marketing emails, however please note that you may continue to receive such communications for a short period after changing your preferences until our systems are fully updated.
We also like to hear your views to help us to improve our Services, so we may contact you for market research purposes. You always have the choice about whether to take part in our market research.
Cookies and similar technologies
Cookies are small text files containing a unique identifier, which are stored on your computer or mobile device so that your device can be recognised when you are using a particular website or mobile app. They can be used only for the duration of your visit or they can be used to measure how you interact with services and content over time. Cookies help to provide important features and functionality on our Websites and Mobile Apps, and to improve your customer experience.
When you consent to cookies on our services, these may be used to do the following:
Improve the way our Websites and Mobile Apps work
Cookies allow us to improve the way our Websites and Mobile Apps work so that we can personalise your experience and allow you to use many of their useful features.
Improve the performance of our Websites and Mobile Apps
Cookies can help us to understand how our Websites and Mobile Apps are being used, for example, by telling us if you get an error messages as you browse.
Deliver relevant online advertising, including via social media
Measuring the effectiveness of our marketing communications, including online advertising
Cookies can tell us if you have seen a specific advert, and how long it has been since you have seen it. This information allows us to measure the effectiveness of our online advertising campaigns and control the number of times you are shown an advert.
Third parties operating through our Websites and Mobile Apps
Our key partners are listed below with information about the services they provide to us. This list is not exhaustive but it does include those partners with whom we have an established relationship and whose cookie technologies are most frequently deployed through our Services.
Measurement & Personalisation
To analyse how our services are used, including to test different content versions. This data may also be used to enable us to personalise our services and the marketing of our services
To contact us via LiveChat
To personalise Krakowsky adverts shown to you via Krakowsky and on other websites based on your interactions with Krakowsky. For example, by using data about your transactions with Krakowsky, what you have in your basket and the pages and products you look at.
To market to you via social media platforms and to enable social sharing and engagement on our websites. These companies may use your data for their own purposes, including to profile and target you with other advertising
Newsletters and emails
To power commenting on our websites
Online transactions and payments
Your choices when it comes to Cookies
Web browser cookies
You can use your browser settings to accept or reject new Cookies and to delete existing Cookies. You can also set your browser to notify you each time new Cookies are placed on your computer or other device. You can find more detailed information about how you can manage Cookies through your browser’s help function.
If you choose to disable some or all Cookies, you may not be able to make full use of our Websites. For example, you may not be able to add items to your shopping basket, proceed to checkout, or use any of our products and services that require you to sign in.
You can also manage advertising related Cookies used on our Services by opting-out through the Service Providers listed in the table above or by visiting the YourOnlineChoices website. Where we display personalised adverts on other organisations’ websites, the AdChoices icon will usually be displayed. Clicking on this icon will provide you with specific guidance on how to control your online advertising preferences. More information is available on the YourAdChoices website.
Cookies work differently on Mobile Apps as they are coded into the App itself and will use a unique identifier created by your mobile device for use for advertising activities. You can turn off or reset this advertising identifier through your mobile device’s privacy settings.
Subject Access Rights
You have the right to see the personal data we hold about you. This is called a Subject Access Request.
If you would like a copy of the personal data we hold about you, please contact us on firstname.lastname@example.org
Other Data Protection Rights
In relation to your personal data, you also have the right to:
1. have inaccurate information corrected:
Summary of the right:
if you believe we hold inaccurate or missing information about you, please contact us and we will correct it.
2. object to our use of it:
Summary of the right:
general objection - We will then consider you objection to our use of your personal data. If on balance, your rights outweigh our interests in using your personal data, then we will at your request either restrict our use of it (see section 3 below) or delete it (see section 4 below).
objection in relation to direct marketing – If you make such an objection, we will stop using your personal data for direct marketing purposes.
3. restrict our use of it:
Summary of the right:
There are several situations when you can restrict our use of your personal data, this includes (but is not limited to):
- you have successfully made a general objection (listed in section 2 above).
- you are challenging the accuracy of the personal data we hold.
- we have used your personal data unlawfully, but you do not want us to delete it.
4. have us delete it:
Summary of the right:
There are several situations when you can have us delete your personal data, this includes (but is not limited to):
- we no longer need to keep your personal data;
- you have successfully made a general objection (listed in section 2 above);
- you have withdrawn your consent to us using your personal data (and we do not have any other grounds to use it);
- we have unlawfully processed your personal data.
5. complain to the data protection regulator:
We’d like the chance to resolve any complaints you have, however you also have the right to complain to the data protection regulator about how we have used your personal data. Please see below for how you can contact the regulator.
More Information on your Data Protection Rights
The website of data protection regulator also contains more detail on the data protection rights mentioned above, or if you would like to speak to us about these rights in more detail, see the “how to contact us” section below.
How to contact us
If you have any questions about how we collect, store and use personal data please contact us.
Phone: +44 (0) 203 286 5538
Write to us at:
Kinly Management Ltd, w Cardiff, 94 Mackintosh Place, CF24 4RR, United Kingdom,