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Privacy Policy

Privacy Policy

This Policy is a separate document and supplements the Public Offer Agreement.

1. General provisions and data controller

1.1. This Privacy Policy (hereinafter — the Policy) explains what personal data we collect, for what purpose, to whom we transfer it, how long we store it, and how you can manage your data.

1.2. The Policy applies to:

  • the website of the online store “Lavka Molfara” https://lavka-molfara.com.ua (hereinafter — the Site);
  • the Seller’s mobile application for Android and iOS (hereinafter — the App);
  • inquiries and orders by phone and via messengers (Telegram, Viber, WhatsApp).

1.3. Personal data are processed in accordance with the Law of Ukraine “On Personal Data Protection” No. 2297-VI and other applicable legislation of Ukraine.

1.4. The controller of personal data (hereinafter — the Seller, “we”) is a sole proprietor, whose details are posted on the Site and in the App in the “Contacts” section.

1.5. By using the Site or the App or placing an order, you confirm that you have read this Policy.

2. What data we collect

2.1. We collect only the data that are necessary for the purposes in section 3.

Category

What data

Source

Contact and delivery details

last name, first name, phone number, email address, delivery address or pickup branch, recipient details

you, when placing an order or making an inquiry

Account data

date of birth, gender (optional — for personalized recommendations and birthday gifts)

you, during registration

Order data

products, amounts, payment and delivery method, order status, waybill number, used promo codes

generated when placing an order

Payment data

payment card details are entered on the bank’s or payment service’s page and processed by it

you, on the payment page

Communication with us

correspondence in messengers and chatbots, recordings of phone calls, survey responses

you, when you contact us

Site technical data

cookies, IP address, browser and device type, pages viewed, referral source (including ad tags)

automatically

App technical data

device model, operating system and App version, push notification token, App usage data, crash reports

automatically

3. Purposes and legal grounds for processing

3.1. We process data on the grounds provided for by Article 11 of the Law “On Personal Data Protection”:

Purpose

Grounds

Placing, paying for and delivering an order, returns and exchanges

conclusion and performance of the contract (Public Offer Agreement)

Consultations, responses to inquiries, service messages about order status

conclusion and performance of the contract

Marketing and informational mailings (promotions, discounts, new arrivals), surveys, giveaways

your consent, which you can withdraw at any time (section 4)

Measuring advertising effectiveness, Site and App analytics

your consent

Personalized recommendations and birthday gifts (if you provided date of birth and gender)

your consent: you provide these data optionally

Service quality control, recording phone calls, fraud prevention

the Seller’s legitimate interest

Accounting and tax records, fiscal receipts

the Seller’s legal obligation

3.2. You give consent for the transfer of your phone number and email in the form of a cryptographic hash to advertising platforms via a separate checkbox when placing an order (clause 9.3 of the Public Offer Agreement); you can place an order without such consent. Hashing does not make data anonymous, therefore such data are processed as personal data. We send marketing and informational mailings only with your prior consent given in written (including electronic) form. You give consent for the use of analytics and advertising cookies via the cookies notice on the Site or in the App. You can withdraw consent at any time in the manner described in sections 4 and 8.

4. Mailings and notifications

4.1. Service notifications about confirmation, payment, shipment, and order status are sent to perform the contract. They do not contain advertising.

4.2. Marketing and informational messages (promotions, discounts, new arrivals) are sent with your consent: by email, SMS, in messengers, via chatbots, and via push notifications in the App.

4.3. You can opt out of marketing messages free of charge and without giving reasons in any of the following ways:

  • click the unsubscribe link or button in the message;
  • disable push notifications in the App or device settings;
  • stop or block the chatbot in the messenger;
  • email us or call the phone number specified in the “Contacts” section.

4.4. Opting out of marketing messages does not affect placing and fulfilling orders. Service messages about an active order will still be sent.

5. To whom we transfer data

5.1. We transfer data only to the extent necessary for the purposes in section 3:

Recipient

Purpose

What data

Delivery services: Nova Poshta, Ukrposhta

delivery, returns, and cash on delivery (COD)

recipient’s full name, phone, address or branch, COD amount

Banks and payment services

payment, refunds, fraud prevention

order and payment data

CRM system

processing orders and inquiries

contact data, order data, correspondence

Mailing and chatbot services: SendPulse

service and marketing messages

name, phone, email, messenger identifier

Messengers: Telegram, Viber, WhatsApp

communicating with you at your request

correspondence; the rules of the messengers themselves then apply

Advertising and analytics platforms: Google, Meta

measuring advertising effectiveness, analytics

cookies and technical data; phone number and email only in the form of a cryptographic hash

Government authorities

only upon a lawful request in cases provided for by law

to the extent of the request

5.2. We transfer data only to recipients who ensure its protection at a level not lower than described in this Policy and use it only for the specified purposes.

5.3. Some of these services (including Google, Meta, SendPulse, and messengers) may process data on servers outside Ukraine. Such transfer is carried out in accordance with Article 29 of the Law “On Personal Data Protection”.

6. Data retention periods and deletion

6.1. We store data no longer than necessary for the purpose of processing:

Data

Retention period

Accounting and tax documents

for the periods established by the legislation of Ukraine

Data for marketing mailings

until consent is withdrawn or you unsubscribe

Account data

until the account is deleted

Cookies

according to the lifetime of each file

6.2. After the retention period expires, the data are deleted or anonymized.

6.3. How to delete your data. Send a request to the email address specified in the “Contacts” section with the subject “Data deletion” and indicate the phone number or email you used for orders. We will delete the data and notify you about it.

6.4. We do not delete data that we are required to retain by law, including accounting and tax documents. Such data are stored until the mandatory period ends and are not used for other purposes.

6.5. Deleting the account. You can delete your account and the data associated with it in the App or by sending a request in accordance with clause 6.3. Along with the account, profile data are deleted, except for those specified in clause 6.4.

7. Data protection

7.1. We take organizational and technical measures to protect data from loss, alteration, and unauthorized access:

  • data are transmitted via secure channels (HTTPS);
  • access to data is granted only to employees who need it for work, and via individual accounts;
  • payment card data are entered on the bank’s or payment service’s page and processed by it;
  • for advertising platforms, phone and email are transferred only in the form of a cryptographic hash.

7.2. If a data breach occurs that creates a risk for you, we will notify you in the manner provided by law.

8. Your rights

8.1. In accordance with Article 8 of the Law “On Personal Data Protection”, you have the right, in particular, to:

  • know what data about you we process, for what purpose, and to whom we transfer it;
  • obtain access to your data;
  • request correction of inaccurate data;
  • request deletion of data or cessation of processing;
  • withdraw consent to processing at any time;
  • object to data processing;
  • file a complaint with the Ukrainian Parliament Commissioner for Human Rights or with a court.

8.2. To exercise your rights, email the address specified in the “Contacts” section. We may ask you to confirm that the request was sent by you. We respond no later than within 30 calendar days.

9. Minors, Policy changes, contacts

9.1. The Site and the App are intended for persons who have reached 18 years of age. We do not knowingly collect data from minors. If we learn that such data have been collected, we will delete them.

9.2. We may update the Policy. The current version always contains the update date. We will notify you of material changes on the Site or in the App.

9.3. For questions regarding personal data, please contact us using the contact details specified on the Site and in the App in the “Contacts” section.

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