1. Processing personal data
The satisfaction of customers is of the greatest importance to Põldma Kaubanduse AS. The company collects and preserves information concerning its customers in order to offer its customers the best service. 1.1 Põldma Kaubanduse AS processes the personal data of the members of the Denim Family loyalty programme on the basis of a valid contract in which the customers have expressed their wish to join the loyalty programme, have completed an application required for that purpose, and have agreed to the terms and conditions of the Denim Family loyalty programme. 1.2 Personal data is classed as being information that Põldma Kaubanduse AS collects in order to be able to identify individuals, to carry out the terms of the contract, and to manage accounts, in which case the contract which has been entered into between Põldma Kaubanduse AS and the customer serves as a legal basis for processing the customer’s personal data, offering products and services which are aimed at the users of the Denim Family programme, conducting surveys, and holding prize draws in accordance with the legislation that is currently in force. 1.3 Põldma Kaubanduse AS processes the personal data of its customers so that it can offer them the best service and the best shopping experience. Põldma Kaubanduse AS processes personal data for such reasons as, for example, collecting information about purchases made, offering targeted products and services, carrying out prize draws, and receiving information concerning the reading and opening of newsletters in order to offer customers content that they may find interesting. 1.4 Põldma Kaubanduse AS processes such personal data that is necessary for it to be able to carry out the terms of the contract and to offer customers the best service. Any details which are submitted by customers are confidential and are preserved securely in accordance with the legislation that is currently in force. Personal data processed within the Denim Family loyalty programme 1.5 When joining the Denim Family loyalty programme, the following personal data as submitted by the customer is processed: gender, given name, surname, personal identification code, date of birth, consent to receive direct marketing, email address, mobile phone number, postal address, and language of communication. 1.6 Põldma Kaubanduse AS has the right to conduct a profile analysis of the card user’s personal data in order to better understand the expectations of customers and, consequently, to be able to offer better products and services by aiming direct marketing more accurately. Forwarding and using personal data within the loyalty programme 1.7 Põldma Kaubanduse AS may forward the personal data of its customers to processors who have been authorised by Põldma Kaubanduse AS, and whose registered locations and data directories are in the European Economic Area. The data processors of Põldma Kaubanduse AS are cooperation partners who implement technical and organisational measures to ensure that the personal data of customers can be processed in accordance with applicable laws. 1.8 Põldma Kaubanduse AS has entered into contracts concerning the confidentiality of personal data with all of the cooperation partners to whom Põldma Kaubanduse AS forwards personal data within its loyalty programme. 1.9 A member of the Denim Family loyalty programme is forwarded information about special offers and discounts, and products and services via electronic channels (including social media) to the telephone number, email address, or postal address presented in the application if the card user has given their consent to receive such offers. 1.10 To receive more detailed information about the data processors of Põldma Kaubanduse AS, contact us by email at: [email protected] Changing personal data 1.11 If Your personal details change in any way, we would ask that You visit Your nearest Põldma Kaubanduse AS store to update Your account or contact us by email at: [email protected] 1.12 Registered users of the online store can view, edit, and supplement their personal data in their Denim Family account. 1.13 When submitting new personal details, the data is updated automatically. Viewing and transferring personal data 1.14 Members of the Denim Family loyalty programme have the right to view their personal data any time and to receive information about their personal data where such data is being processed by forwarding a digitally-signed request to Põldma Kaubanduse AS at: [email protected] Withdrawing consent to the processing of personal data, and deleting personal data 1.15 Members of the Denim Family loyalty programme have the right to withdraw their consent to direct marketing (including discount offers, campaigns, or newsletters) at any time by logging into their online store account and doing it there or by forwarding this request via email at: [email protected] 1.16 Denim Family has the right to refuse to satisfy a request to delete personal data if it is necessary to process the card user’s personal data in order to prepare, file, or defend legal claims in connection with the protection of persons or assets or other necessities which are prescribed by law. In such cases, Põldma Kaubanduse AS has the right to preserve the personal and shopping details of the card user for up to twenty-four months after the last use of the card, and the personal data will be deleted automatically upon the expiry of this period. The preservation of personal data within the loyalty programme 1.17 Within the loyalty programme, the personal and shopping details of the card user are preserved according to the requirements of the Accounting Act; personal data is deleted automatically upon the expiry of the card or the period detailed above. Personal data is deleted before the expiry of this period if the card user submits a corresponding request to Põldma Kaubanduse AS and if the deletion of such data does not come into conflict with other legislation. The controller of personal data within the loyalty programme and the resolution of disputes 1.18 Within the loyalty programme, Põldma Kaubanduse AS is classed as being the controller of personal data. Within the loyalty programme, Põldma Kaubanduse AS has the right to forward personal data to processors who are cooperation partners in order to offer card users the best service. Processors have the right to process personal data only according to the instructions which are received by them from Põldma Kaubanduse AS, and they are obliged to guarantee the protection of personal data. Personal data processors and their contact details 1.19. If card users have any questions about the processing of their personal data within the loyalty programme, they can contact the data protection specialist who has been authorised by Põldma Kaubanduse AS any time at: [email protected] 1.20. If you find that Your rights are being violated while processing Your personal data within the loyalty programme, You have the right to seek satisfaction via the Data Inspectorate and the courts.
2.1 The personal details of customers that have become known to us via visits to and purchases from Põldma Kaubanduse AS’s stores or via the online store are handled as confidential information. 2.2 Access to Põldma Kaubanduse AS’s customer details in order to amend and process details is only granted to individuals who are authorised for that purpose. 2.3 During the course of our activities, we make sure that those activities conform with all relevant activities and the corresponding legislation of the European Union and the Republic of Estonia.
3. General information
3.1 The Denim Family loyalty programme is the joint loyalty programme of all stores which operate under the following names: Denim Dream, Guess, Tommy Hilfiger, Calvin Klein, Mustang, Tom Tailor, Camel Active, Desigual and Premiere, all of which are part of the Põldma Kaubanduse AS group. 3.2 The purpose of the loyalty programme is to identify the members of the Denim Family and reward them with discounts and special offers. 3.3 AS Põldma Kaubandus is responsible for maintaining the confidentiality of the Denim Family loyalty programme, customers, and users; registry code: 10103586; address: Ehitajate tee 120, 13570, Tallinn. 3.4 Põldma Kaubandus has the right to change the loyalty programme and the discounts offered within that programme. Contact If you have any questions or concerns, please contact us at [email protected] Address: Ehitajate tee 120, Tallinn, Estonia Telephone: + 372 67 200 67
4. Processing personal data
Personal data being used by the online store denimdream.com is under the control of Põldma Kaubanduse AS (registry code 10103586) which is located at Ehitajate tee 120, telephone number 6720067, email address [email protected] As the data controller, Põldma Kaubanduse AS has appointed a data protection officer who can be contacted by calling 6720067 or by sending an email to [email protected] The type of personal data being processed: 1. name, phone number and email address; 2. delivery address; 3. bank account details; 4. the cost of products and services, and payment information (purchase history); 5. customer support details. The purpose of processing personal data Personal data helps the controller to manage the customer’s orders and goods deliveries. Purchase history data (including the date of purchase, the name and quantity of the goods, and customer data) are used for generating an overview of the goods and services which have been purchased or used, and for analysing customer preferences. The bank account number is used for returning payments to the customer. Personal data such as email address, phone number, and the name of the customer are processed for the purpose of resolving issues which are related to providing goods and services (customer support). The IP address or other online identifiers of the users of the online store are processed in order that an online store service can be provided as an information society service, and for generating statistical data regarding web use.
5. Legal basis
Personal data is processed for the purpose of the performance of the contract which has been entered into with the customer. Personal data is processed for the purpose of fulfilling legal obligations (e.g. bookkeeping and resolving consumer complaints). With the consent of the customer, personal data is processed for the following purposes: Põldma Kaubanduse AS processes the customer’s personal data in order to provide the best service and shopping experience. Põldma Kaubanduse AS processes the customer’s personal data in order to, for example, collect information about purchases which have been made, send out targeted product and service offers, organise lotteries, and regarding the reading and opening of newsletters to provide the customer with content that is attractive to that customer. Based on the personal data in the Denim Family loyal customer programme, Põldma Kaubanduse AS engages in profiling in order to better understand customer expectations and to improve the quality of its products and services. Profiling also allows for a more precise targeting of direct marketing.
6. Recipients of personal data; data security and access to data
Personal data are disclosed to the customer support department for the online store, for the purpose of managing purchases and purchase history, and for resolving customer issues. The name, phone number, and email address are submitted to the transport service provider that has been chosen by the customer. If the goods are to be delivered by courier service, the contact data submitted will also include the customer’s address. If the bookkeeping of the online store is handled by a service provider, then personal data will be submitted to the service provider for the purpose of providing bookkeeping services. Personal data may be submitted to information technology service providers if this is necessary in order to ensure the functionality of the online store or data hosting. Personal data are stored on the servers of Põldma Kaubanduse AS which are located within the territory of an EU or EEA member state. Data may be submitted to countries with a sufficient level of data protection as per the assessment of the European Commission, and to US companies who are certified under the Privacy Shield Framework. Access to personal data is granted to the employees of the online store who can examine the personal data in order to resolve technical issues which are related to the use of the online store and to provide a customer support service. The online store will apply relevant physical, organisational, and IT security measures in order to protect the personal data from accidental or unlawful destruction, loss, or amendment, and any unauthorised access or disclosure. Upon the submission of personal data to the processors who have been appointed by the online store (e.g. transport service providers and data hosting), personal data is processed on the basis of agreements which have been entered into between the online store and the processors. The processors must ensure the use of relevant safeguards when processing personal data.
7. Examination and rectification of personal data
Personal data may be examined and rectified via the user profile on the online store. If a purchase has been made without a user account, personal data may be examined via customer support. The withdrawal of consent If personal data are processed on the basis of consent, the customer may withdraw their consent by notifying customer support via email. The retention of personal data Upon closing a customer account with the online store, personal data are deleted unless such data need to be retained for the purposes of bookkeeping or to resolve consumer complaints. If the purchase was made from the online store without a customer account, the purchase history will be retained for three years. In cases of disputes arising which are related to payments and consumer complaints, personal data are retained until the claim is satisfied or the limitation period has passed (this being three years). Personal data which are necessary for the provision of bookkeeping services are retained for seven years. Deleting personal data In order to have personal data deleted, customer support must be contacted via email. The response to the deletion request will be provided within one month, specifying the data deletion period. Transferring personal data The response to a request for transfer which is submitted via email will be provided within one month. The customer support department identifies the person and provides notification of the data which is to be transferred.
8. Direct marketing messages; contact
The email address and phone number are used for sending out direct marketing messages only if the customer has provided their consent. A customer who does not wish to receive direct marketing messages must click on the respective link in the email or contact customer support. If personal data are processed for the purpose of direct marketing (profiling), the customer may object to any initial and further processing of their personal data, including profiling which is related to direct marketing, at any time by notifying the customer support of this requirement via email. Settling disputes Any disputes which are related to the processing of personal data will be resolved via customer support (email: [email protected]). The supervisory authority is the Estonian Data Protection Inspectorate ([email protected]). Contact Email: [email protected] Phone: + 372 67 200 67
9. Delete account
To delete account it's needed to go under "My account" and click "Delete account". This will also delete all personal data.