You acknowledge and agree that the personal data collected about you may be used by Näak Inc. in accordance with the terms of this Policy.
This Policy applies to personal data collected when using products and services offered by Näak or in other interactions with us where a link or other reference is made to the inclusion of this Policy. This may include, for example, personal data collected in connection with the use of our products, websites, applications and other services generally offered by Näak in electronic form, as well as other customer support and warranty services, customer events, promotions and campaigns.
Where a consent from you to the processing of personal data described in this Policy is required under the applicable law, such consent will be obtained by appropriate mechanism such as ticking a box stating your consent, choosing technical settings for a service or website, or other statement or conduct clearly indicating your acceptance to the processing, depending on the product, website, service or application you are using.
In general, we collect your personal data when you make a purchase related to our products or services, use or subscribe to our services, participate in a sales promotion or campaign, or otherwise interact with us.
For the most part, you can visit our websites or use our products or services without having to identify yourself. However, certain technical information is normally collected as a standard part of using our services. This information includes, but is not limited to, your IP address, access times, device information and other technical information provided to us by your browser or otherwise collected in connection with the use of certain products and services. When you use our services, or otherwise interact with us over telecommunications networks, certain additional information, such as your mobile subscription number, may be transmitted to us by your operator as a standard part of that communication.
INFORMATION YOU PROVIDE US
When you register to our services, make a purchase, participate in a sales promotion, or otherwise interact with us, we may ask you to provide us with certain information such as your name, e-mail address, mailing address, and user names, passwords, and other identifiers used to authenticate users and validate their actions. This information may also be necessary in order to provide you with the products and services you have requested, or otherwise to communicate with us. We may also collect learning data, demographic information such as your age, gender, zip code, and language preferences.
We may also collect other information that you provide to us, such as your agreements, preferences and comments, data relating to your devices, etc. We may also collect other information that you provide to us. Please note that some of the non-identifiable information collected may become identifiable when you submit your personal data to us. Some of our services may allow you to submit information about others, for example if you place an order for a product that you wish to have sent directly to another recipient.
YOUR TRANSACTIONS WITH US
We collect or request information relating to your purchases or use of our products or services and your other interactions with us. This information may, for example, include details of requests or enquiries you have made, products or services provided (including delivery details). It may also include details of your purchases (including payments made, credit card information, billing address, credit check information and other financial information). It may also include details of agreements between you and Näak, records of contacts and communications, information and details relating to content you have provided to us and other transactional information. We reserve the right, in accordance with applicable law, to record your communications with our customer service or other similar contact points.
DATA OBTAINED FROM THIRD PARTIES
In addition to the personal data you provide us, we may obtain, in accordance with applicable laws, certain personal data from mailing list rental companies and any other publicly available sources. This data may include personal data such as information relating to your creditworthiness and updates to your address information.
THE PURPOSES FOR WHICH WE PROCESS YOUR PERSONAL DATA
Näak processes your personal data and/or any other confidential service-specific information for the purposes described in this Policy. Please note that different purposes may apply simultaneously.
PROVISION OF PRODUCTS AND SERVICES
We may process and use your personal data in order to provide you with the product or service you have requested, to respond to your requests, such as customer service, to process your order or for any other purpose necessary for the fulfilment or performance of the contract between you and Näak. We may also process and use your personal data to ensure the functionality and security of our products and services, to identify you and for the prevention and detection of fraud and other abuses.
DEVELOPMENT OF PRODUCTS AND SERVICES
We may process and use your personal data in order to develop our products and/or services. However, as a general rule, for the development of our products and services, we only use aggregate data and statistics, and not data that can directly identify you. We may also use your personal data in order to personalise our offer and provide you with a better service, for example, to make recommendations and display personalised content and advertising. We may combine personal data collected in connection with your use of a specific Näak product and/or service with other personal data held about you, except where such personal data has been collected for other purposes.
COMMUNICATING WITH YOU AND MARKETING
We may process and use your personal data in order to communicate with you, for example, to provide you with information about the Näak products and/or services you use or to ask you to participate in customer satisfaction surveys. We may process and use your personal data for marketing purposes, which may include the use of your personal data for personalised marketing or research purposes, for example, in accordance with applicable law, to conduct market research and to keep you informed about our products, services or promotions via our own or third party electronic services or other services.
In addition, some of our products and services may be used to promote the products and services of other companies. However, Näak will not disclose your personal data to these companies for marketing purposes without your prior consent.
We may process and use your personal data for the purposes of profiling / personalisation, targeted direct marketing and optimisation of our products and services. We may also create consolidated and statistical information based on your personal data. Profiling / personalisation includes the automated processing of your personal data in order to evaluate, analyse and anticipate your preferences and interests, for example, to communicate marketing messages to you regarding products or services best suited to your needs.
TRANSFERS OF YOUR PERSONAL DATA
We may disclose your personal data to third parties only in accordance with the terms of this Policy set out below, or as required by law.
You can unsubscribe from the brand's marketing e-mails by following the instructions contained in those e-mails (usually provided via the "unsubscribe" link) or by contacting the contact details provided in the e-mail and on our website. If you choose to unsubscribe, we may continue to send you non-marketing emails, such as service notifications or other information, or if you are a corporate customer, we may send you marketing information.
SERVICE PROVIDERS AND OTHER AUTHORIZED THIRD PARTIES
We may transfer your personal data to authorized third parties who process personal data on behalf of Näak for the purposes described in this Policy. These third parties may include technical, logistics, e-commerce, marketing or other service providers. These third parties are not permitted to use your Personal Data for purposes other than those for which your data was collected, and we require them to act in accordance with applicable laws and the terms of this Policy, and to implement appropriate security measures to protect your Personal Data.
Our products and services may be provided through resources and servers located in different countries around the world. As a result, your personal data may be transferred outside the country where you use our services, including countries outside the European Economic Area (EEA), whose level of data protection may be deemed inadequate by the European Commission. In such cases, we take the necessary measures to ensure that an adequate level of protection for your personal data is provided in accordance with applicable laws. With regard to international transfers of your personal data, we generally rely on agreements based on the Standard Contract Clauses ("SCCs") defined by the European Commission. You can consult these SCCs on the website.
We may need to disclose and process your personal data in accordance with applicable laws in order to defend Näak's legitimate interests, for example, in civil or criminal legal proceedings.
MERGERS AND ACQUISITIONS
In connection with a sale, redemption, merger, acquisition or other reorganization of our business in certain countries, we may disclose personal data to prospective or existing purchasers and their advisors or receive personal data from sellers and their advisors for the purposes of such transaction.
DATA CONCERNING MINORS
Näak does not seek to collect data from or engage in transactions with persons under the legal age in their country. However, our databases may contain personal data relating to children, as it is not always possible to determine the user's age accurately. We reserve the right to block access to the service to any person who is or is reasonably presumed to be a minor.
It is Näak's policy to instruct minors not to make purchases or engage in any legal transactions in connection with our products and services without the consent of a parent or legal guardian, unless permitted by applicable law. Minors with the consent of their legal guardian must be able to provide proof of such consent upon request.
DATA QUALITY AND RETENTION
We take reasonable steps to maintain the accuracy of the personal data in our possession and to keep it up to date. Accordingly, we delete any personal data that is out of date, incorrect or unnecessary.
Some Näak products and services may allow you to manage your profile and the information contained therein. Therefore, we invite you to regularly access your personal data to check that it is accurate and up-to-date. With regard to these electronic services allowing you to manage your profile, please note that it is your responsibility to provide us with accurate information and to update the personal data provided in the event of changes.
We retain your personal data only for as long as is necessary for the relevant purposes or as long as required by applicable law.
Näak implements appropriate technical and organisational security measures in order to prevent and minimise risks in connection with the provision and processing of personal data.
These security measures include, where appropriate, the use of firewalls and secure servers, encryption, deployment of appropriate access rights management systems and procedures, careful selection of processors, adequate training of Näak personnel responsible for processing personal data, and other measures necessary to ensure that your personal data is adequately protected against unauthorized use or disclosure. If necessary, we may also make back-up copies and use other means to prevent accidental damage or destruction of your personal data.
You have the right to request information and to access the personal data collected about you. You may also request to complete, rectify, make anonymous or delete any incomplete, inaccurate, unnecessary or obsolete personal data held by us about you. However, we cannot proceed to the deletion of personal data necessary to comply with legal obligations or when the retention of such data is necessary in accordance with the laws in force. You may request to receive the personal data collected about you in a commonly used, machine-readable format. When you consider the personal data collected about you to be inaccurate, when you do not wish your personal data to be deleted when their processing has been deemed unlawful or when such data is no longer required, or when you have objected to the processing of such data and when the existence of grounds for legitimising the processing of such data is being examined, you have the possibility to request the restriction of the processing of your personal data.
You may also, at any time, object to the processing of your personal data for the purposes of direct marketing, or in order to stop receiving commercial promotions, being profiled or participating in market research. In addition, once you have consented to the processing of your personal data, you may withdraw your consent at any time.
In the event that you wish to exercise your rights mentioned above, you may, if necessary, and in accordance with the laws in force, contact us via the contact points mentioned in our commercial documents or at the contact details indicated below. In some cases, in particular if you wish to delete or terminate the processing of your personal data, we may no longer be able to continue to provide you with certain services. We invite you to use our profile management tools available to you for the purposes indicated above. Indeed, these tools allow you to directly access and manage your personal information in an efficient manner.
Please note that in order to respond to any of the above requests, Näak may need to identify you and request additional information from you. Please also note that applicable laws may contain restrictions and other provisions relating to your rights set out above.
COMPLAINT TO THE DATA PROTECTION SUPERVISORY AUTHORITY
If you consider the processing of your personal data by Näak to be incompatible with the applicable data protection laws, or if you consider that Näak does not sufficiently safeguard your rights, you have the possibility to lodge a complaint with the local data protection supervisory authority.
Näak may from time to time update and make changes to this Policy. If these changes include new purposes for data processing, Näak will notify you in advance of these changes and, where necessary, seek your consent.
14 July 2020 (updated on 15 July 2020)