We (Kelkoo) take the privacy rights of users of our website www.ciao.es (the “Website”) very seriously and are committed to protecting and respecting your privacy.
WHO ARE WE?
Any Personal Information you provide to us is held by Kelkoo SAS, a company registered in France with company number 425 093 069, whose registered office is situated at 12, rue Godot de Mauroy, 75009, Paris, France.
DATA PROTECTION OFFICER AND LEAD SUPERVISORY AUTHORITY
We have appointed a Data Protection Officer and you can contact him for any further queries you have in relation to the data processing we carry out directly by email (email@example.com).
As the main establishment of the controlling undertaking of the Kelkoo group for data processing purposes is situated in France, the French Data Protection Authority: Commission Nationale Informatique et Libertés, 3 Place de Fontenoy - TSA 80715 - 75334 Paris CEDEX 07, France, is competent for the cross-border personal data processing we carry out.
“Personal Information” means any information about you which is personally identifiable which may include (but might not be limited to) your name, age, gender, location, telephone number, email address, IP address, financial details and any other information from which you can be identified directly or indirectly and which you may disclose to us or otherwise provide to us via the Website or elsewhere at any time.
WHEN DO WE COLLECT YOUR PERSONAL INFORMATION?
We may collect and process Personal Information based on your consent when:
• you view or buy a product or service from a merchant listing its offers on our Website or through one of our business partners;
• you make a complaint or enquiry or provide feedback to us;
• you provide account information when you register or sign in to your user account with us in order to use certain services, such as the Kelkoo Newsletter, the User Reviews or when you enter into any competition, promotion, prize draw or survey on the Website;
• you disclose Personal Information to us at any point.
We will indicate where the provision of Personal Information is optional. If you choose not to provide such Personal Information, you may find that some services or use of features on the Website are unavailable to you.
HOW DO WE USE YOUR PERSONAL INFORMATION?
We may use your Personal Information in the following ways:
• for fraud prevention and security on our Website and systems;
• to help us understand what products you have viewed or purchased through the Website in order to provide a better and more personalised service to you, including advising you on and offering to you products, services, content and special offers;
• to analyse the use of the Website and of the websites of our merchants and business partners, including user demographics, interest and behaviour to optimise the services we offer;
• to allow you to participate in certain services we offer such as the Kelkoo Newsletter, the User Reviews or any competition, promotion, prize draw or survey launched on the Website or to inform you of changes to any of these services;
• to process registration of your account information and maintain the user account you may have with us;
• to ensure that your purchase has been duly completed on the merchant’s or business partner’s website.
DO WE SHARE YOUR PERSONAL INFORMATION WITH THIRD PARTIES?
We may pass on your Personal Information to other parties as follows:
• to selected and trusted third parties who may use your Personal Information to provide you content (including advertising content) that may be of interest to you;
• to business partners to assist us in providing services on our Website and any related services to you. Such business partners are required to maintain the confidentiality of your Personal Information and, unless you are otherwise advised, do not have any rights to use the Personal Information about you that we provide to them for any purpose beyond what is necessary to assist us;
• some aggregated information about the Website users, sales patterns, traffic volumes and related matters to reputable third parties but these details will not include any of your Personal Information;
• to any member of the Kelkoo group; and
• in the event that we sell or buy any business or assets, in which case we may disclose your Personal Information to the prospective seller or buyer of such business or assets on a confidential basis.
HOW DO YOU EDIT AND DELETE YOUR INFORMATION?
HOW LONG DO WE HOLD PERSONAL INFORMATION FOR?
We only hold Personal Information for as long as is necessary for the purposes described above in the paragraph headed “HOW DO WE USE YOUR PERSONAL INFORMATION?”
HOW DO WE PROTECT PERSONAL INFORMATION?
We employ all industry standard practices and have strict security procedures covering the collection, storage and disclosure of Personal Information in order to prevent unauthorised access and to comply with relevant European and local data protection laws. All Personal Information you provide to us is stored on our or our business partners’ secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
WHAT ARE COOKIES AND WEB BEACONS AND HOW DO WE USE THEM?
WHERE DO WE STORE PERSONAL INFORMATION?
ACCESS TO INFORMATION
You have the right to access Personal Information held by us about you. If you would like to receive a copy of your Personal Information held by us, please write to our Data Protection Officer at the address above mentioned.
We will provide the Personal Information held by us about you within one month following your request. Such timeframe may be extended to three months considering the complexity of your request and you will be informed of such extension.
In case of reasonable doubt about your identity, we may ask you to provide us with additional information.
We may charge you a reasonable administrative fee to meet our costs in providing you with details of your Personal Information which we hold if we find your request manifestly excessive or repetitive.
OTHER RIGHTS THAT YOU HAVE
In addition to the right of access detailed below, you can exercise the following rights by writing to our Data Protection Officer:
• Right to rectification: you have the right to obtain the rectification of inaccurate/incomplete Personal Information;
• Right to erasure: you have the right to have the Personal Information that we hold about you to be erased without undue delay if (a) this Personal Information is no longer needed for the purposes described in section “HOW DO WE USE YOUR PERSONAL INFORMATION”, (b) you have withdrawn your consent to the processing of your Personal Information by us or you have objected to the processing of your Personal Information by us, (c) you consider that the Personal Information which we hold about you has been unlawfully collected, (d) if the erasure is required pursuant to a legislation which we are subject to, (e) the Personal Information has been collected in relation to a child under 16 years old;
• Right to restriction: you have the right to obtain restriction of the processing of your Personal Information (a) when you contest the accuracy of your Personal Information or you object to the processing by us of your Personal Information - such a restriction will take place for a period enabling us to check the accuracy of said Personal Information or to check the existence of any legitimate grounds for us that could override your rights, (b) when you consider the Personal Information held by us about you has been unlawfully collected but request restriction of its use instead of its erasure, (c) when we no longer need the Personal Information but it is required for you to establish, exercise or defend a legal claim.
• Right to data portability: you have the right to receive the Personal Information held by us about you in a structured, commonly used and machine-readable format and have the right to transmit this Personal Information to another provider or to have your Personal Information transmitted directly by us to another provider, where technically feasible.
We will inform each recipient to whom your Personal Information has been disclosed of any rectification/erasure/restriction that you previously requested, unless it is impossible or it involves disproportionate efforts on our part.
POSTING PERSONAL INFORMATION ON PUBLICLY ACCESSIBLE AREAS
A publicly accessible area of the Website is any area that is accessible by the general public and may be indexed by search engines. You are solely responsible for any Personal Information that you disclose and disseminate on publicly accessible areas. You should never disclose Personal Information relating to any other person without their express consent.
Our Website may, from time to time, contain links to and from the websites of our business partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any of your Personal Information to these websites.
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