Introduction
Kara-Ka knows that it is important for you how your personal data is used and we appreciate the importance of protecting your privacy.
This Privacy Statement explains how Kara-Ka Ltd. collects and manages your personal information. The statement contains information about what data we collect, how we use it, why we need it, and how it can help you.
Contact us at the following email address: office@kara-ka.com if you have any further questions and comments or if you have a claim regarding any of your rights as a data subject.
This Privacy Statement was last updated on December 5, 2018.
Basic principles and our commitment to data privacy protection
We are dedicated to protecting your privacy. We aim to protect all personal data owned by us, to manage your personal data responsibly and to be transparent in our practices. Your trust is important to us. Therefore, we have devoted ourselves to the following basic principles:
• You are under no obligation to provide any personal data requested by us. However, if you choose not to provide information, we may not be able to provide you with certain services or products;
• We only collect and process your data for the purposes set out in this Privacy Policy or for specific purposes that we share with you and/or for which you have agreed to;
• Our goal is to collect, process and use as little personal data as possible;
• When we collect your personal data, our goal is to keep them as accurate and up-to-date as possible.
• If the personal data we collect is no longer required for any purpose and the law does not oblige us to protect it, we will do our best to erase, destroy or permanently disidentify it.
• Your personal data will not be shared, sold, leased or disclosed in any manner other than that described in this Privacy Statement.
What personal data do we collect?
The personal data we collect depends on the purpose of collection and the product or service we provide to you.
We can collect the following types of personal data directly from you:
1. Personal contact information, such as your name, email address, physical address, and phone numbers;
2. Account login details such as your user ID, username, and email password. These details are needed to create a personal user account on one of our online communities;
3. Communication with us, which may include details of our chat, service line and/or customer service lines;
4. Demographic information, such as your age and gender and lifestyle preferences. Lifestyle preferences may include your preference for some of our products and your interests related to the above-mentioned products;
5. Browsing history, such as visited pages, date of visit, location of visit, and IP address;
6. Payment information for purchases made at one of our online stores. Payment information is generally associated with your billing name, billing address, and payment data, such as your credit card details or bank account number.
7. Information about your health;
8. Information about people different from you, such as personal information about your family members when you provide similar information directly to us;
9. Profiles on social media;
10. If you have ever applied for work position in our company, we will collect additional personal data, such as your previous work experience, education, and performance.
In addition, we may also collect personally identifiable information about you when:
1. you share content on social media pages, websites or apps related to our products or in response to our social media promotional material; or
2. we read or collect personal information about you by reading information obtained from other websites (for example, we may post a third-party website listing and when you click on this ad we may receive information about you and other visitors on the website to measure the reach and success of this ad).
Why do we collect and use your personal information?
We collect your personal data to be able to provide you with the best online experience and give you with high quality customer service. In particular, we may collect, hold, use and disclose your personal data for the following purposes:
1. To process your payments if you purchase our products in order to provide you with the status of your order, to process your inquiries and requests, and to access and process any complaints;
2. To process and respond to your inquiries or to contact you to answer your questions and/or requests;
3. To process and refine our products, services, methods of communication and the functionality of our website;
4. To let you know and manage your registration and/or subscription to our newsletters or other messages;
5. To manage our everyday business needs related to your participation in our games, raffles or promotional activities or queries;
6. To verify the identity of individuals who contact us by telephone, electronic means or otherwise;
7. For purposes of internal training and quality assurance;
8. To understand and access interests, desires, and changing customer needs in order to improve our website, our current products and services, and/or develop new products and services;
9. To provide personalized products and communications, as well as product recommendations to you as customers;
In addition, we may require your personal data to be in accordance with legal obligations or in the context of a contractual relationship we have with you.
When we collect and use your personal data for the above-mentioned purposes or other, we will inform you in advance or during the collection of this data.
Where applicable, we will request your consent to the processing of your personal data. When you have given your consent to processing activities, you have the right to withdraw your consent at any time.
Your rights
When we process your personal data, you have a number of rights that you can exercise at any moment. Below we provide an overview of these rights, along with the consequences for you.
To declare your desire to realize your rights as a data subject, download, fill in and sign this Application here and send a scanned copy to the following email address: office@kara-ka.com. If sending an electronic copy is a problem for you, you can either submit your application personally or send it by post with a receipt or courier to the official address for correspondence with Kara-ka Ltd. - Sofia 1836, Levski D, block 45, floor 3. In order to comply with the statutory deadline for replying, the date of receipt of the Applications submitted to the physical address will be the dates indicated in the incoming number or in the acknowledgment of the receipt.
If you submit the Application on behalf of another person, please, send a copy of the written consent to submit the Application on behalf of the data subject and/or the power of attorney together with this document.
If you have further questions about how you can exercise your rights, contact us at the following email address: office@kara-ka.com.
Right of access to your personal data and correction
You have the right to access, correct and update your personal data at any time. To exercise your right, follow the procedure outlined above in the introduction to "Your Rights" section.
Right to data portability
Your personal data is portable. This means that it can be moved, copied or transmitted electronically. However, this right is only applicable when:
a) Processing data is based on your consent;
(b) Processing data shall take place in connection with the performance of a contract;
(c) processing data shall be conducted by automated means;
To exercise your right, please, follow the procedure outlined above in the introduction to "Your Rights" section.
Right to delete your personal information
You have the right to request the deletion of your data if:
1. your personal data is no longer needed in connection with the purposes for which we have collected it; or
2. withdraw the consent you have previously given us for the processing of your personal data and if there is no longer a legal basis for the processing of the above-mentioned personal data; or
3. you express an objection to the processing of your personal data for direct marketing purposes; or
4. you express an objection to the processing of your personal data in Kara-Ka's legitimate interests (such as improving the overall user experience of websites);
5. the personal data is not processed in a lawful manner; or
6. your personal data must be deleted to comply with the law.
In order to exercise your right, please, follow the procedure described above in the Introduction to “Your Rights“ section, and we will take appropriate measures to respond to your request in accordance with the legal requirements.
If the personal data we collect is no longer required for any purpose and the law does not oblige us to keep it, we will do our best to erase, destroy or disidentify it for good.
Right to restrict the processing of personal data
You have the right to restrict the processing of your personal data if:
1. You do not believe that the personal data we hold for you is correct; or
2. The personal data is not processed legally, but instead of it being deleted, you would prefer to restrict its processing; or
3. We no longer need your personal data for the purposes for which we have collected it, but you request data for the purpose of filing, exercising or protecting legal claims; or
4. You have objected to the processing of your personal data and you are awaiting confirmation that your interests in relation to such an objection take precedence over the legitimate grounds for processing your data.
If you wish to restrict our processing of your personal data, follow the procedure described above in the Introduction to “Your Rights“ Section, and we will take appropriate measures to respond to your request in accordance with the legal requirements.
Right of objection
You have the right to object to processing your personal data at any time. To exercise your right, please, follow the procedure outlined above in the introduction to "Your Rights" section.
Right to lodge a complaint with a supervisor
You have the right to file a complaint on the manner we handle personal data directly with a supervisor . To exercise your right, please, follow the procedure outlined above in the introduction to "Your Rights" section.
How we protect your personal information
We understand that the security of your personal data is important. We make every effort to protect your personal data from misuse, interference, loss, unauthorized access, modification or disclosure. We have implemented a number of security measures to help protect your personal data. For example, we apply access controls, we use firewalls and secure servers, and we also encrypt personal data.
Sharing your personal information
When we share your personal data with affiliates and other organizations, we make sure that such procedure is realized only with organizations that protect your personal data and adhere to the applicable privacy laws in the same or similar way as we do.
Your personal data will not be shared, sold, hired, or disclosed in a manner other than that described in this Privacy Statement. However, we may share your data when required by law and/or by the government.
International data sharing
Personal data may be processed outside of the European Economic Area (EEA). For processing it outside the EEA, Kara-Ka will ensure that such cross-border processing is protected by adequate secure measures.
The security tools we use to protect cross-border processing include:
1. Exemplary contractual clauses approved by the European Commission. These standardized contractual clauses provide sufficient secure measures to meet the adequacy and security requirements of the European Data Protection Supervisor (GDPR); or
2. Certifications showing that third countries outside the EEA process personal data in a way that is compatible with the European Data Protection Supervisor. These certifications are approved either by the European Commission, a competent oversight body, or a competent national body for GDPR.
Automated decision making and profiling
For some services and products we can process your personal data by automation.
In addition, we may process your personal data for profiling purposes to predict your behavior on our website or products that may be of interest to you.
If we intend to use such methods, we will, of course, inform you and give you the opportunity to express your objection to these processes beforehand.
Cookies and other technologies
Moreover, we may collect personal information about you by using cookies and other technologies. This can happen when you visit our third-party sites or sites, which appear when you browse our online promotions or when you use our mobile apps or third-party mobile apps. These may include the following information:
a) Information about the browser and the operating system of your device;
b) IP address of the device you are using;
c) Webpages viewed by you;
d) Links you click while interacting with our services.
Please, see our Cookie Declaration for further information in relation to the one described above.
How to contact us
If you have any questions, comments or complaints about this Privacy Statement or the processing of your personal data, please, contact us at office@kara-ka.com.