Limited Liability Company "PRĀNA Ko"
The purpose of this Policy is to provide PRANA’s users with information about types of personal data, procedure, objectives and grounds for their processing, as well as about rights of physical persons as data subjects.
This Policy is drafted in Latvian and translated into other languages for the convenience of the users. In case there are discrepancies of the definitions, or differently written passages, the Latvian text shall have a priority.
1. GENERAL DATA PROTECTION REGULATION ON THE PROTECTION OF INDIVIDUALS WITH REGARDS TO THE PROCESSING OF PERSONAL DATA AND ON THE FREE MOVEMENT OF THESE DATA
PRANA carries out processing of personal data according to the provisions of the General Data Protection Regulation on the protection of individuals with regards to the processing of personal data and on the free movement of these data (hereinafter – GDPR or the Regulation) which came into force on May 25, 2018. The Regulation defines principles of the personal data processing (including obtaining, use, storage and destruction) and rights of physical persons as data subjects, i.e. possibility to control the use of their data.
2. WHAT IS PERSONAL DATA
Personal data is any information (written, audio, video, electronic, biometric) that directly or indirectly relates to an identified or identifiable individual (data subject), for example: name, surname, identification number, birth data, telephone number, postal address or e-mail address, photo, one or several economic factors typical of the physical person and other information that makes it possible to identify the latter.
3. WHAT IS PERSONAL DATA PROCESSING
Personal data processing is any operation performed with personal data with or without use of automation means, for example: collection, registration, organization, structuring, storing, customization or modification, obtaining, viewing, use, disclosure by means of sending, distributing or otherwise making them available, matching or combining, restriction, erasing or destruction.
4. WHO IS A PERSONAL DATA SUBJECT WHOSE DATA IS PROCESSED BY PRANA
A personal data subject is any physical person who:
• has been registered on PRANA’s homepage, or;
• has required information from PRANA about goods offered for sale on PRANA’s homepage or about services provided by PRANA, or;
• uses or has used services provided by PRANA, or;
• has given its consent for receipt of commercial messages from PRANA, including messages about news, sales, events, discounts, contests, lotteries or draws, as well as for tracking (profiling) of shopping habits in order to obtain personally prepared offers, or;
• has expressed its consent for participation in PRANA (user) loyalty programs (hereinafter - User).
5. WHAT PERSONAL DATA IS PROCESSED BY PRANA
PRANA collects personal data from the following sources: from the User itself, from PRANA’s websites on social networks.
This is the information you provide when you:
• register on PRANA homepage, platform,
• fill out the forms,
• use the contacts in messengers or social network,
• send us an e-mail or write to us in a different way,
• sign up for our services,
• are looking for products or services on PRANA platforms,
• place an order on PRANA platform,
• participate in sales promotion or survey,
• send us a request or
• notify about a problem with our platforms.
The information you provide to PRANA can contain the following personal data:
• identification data, for example: name, surname, date of birth, personal code or verification number;
• contact information, for example: telephone number, e-mail address, postal address, communication language with the User.
• data necessary for entering the system and the password.
During registration, the personal data specified in the registration application form is processed. The provision of this personal data is mandatory. You can submit other additional information voluntarily while using our platform.
You can supplement and modify all the data specified in the User's record entry.
5.2. PRANA automatically collects data obtained by the User when visiting PRANA homepage and stores the data for as long as we need it in accordance with the purpose for which it was obtained and as permitted or required by law.
This information includes:
• information of technical nature;
• information about your visit.
The technical information may include the address of the Internet Protocol (IP) used to connect your computer to the Internet, your login details, browser type and version, time zone settings, types and versions of browser plug-ins, operating system and platform.
Information about your visit may include full unified resource generators (URLs), transition flow to our website, through and from it (including date and time), what items you have viewed, what you have been looking for, page reference time, download errors, the length of time you have visited the page, information about your interaction with the webpage (such as scrolling, clicks and setting the mouse pointer), the methods used for transition from the webpage, and any telephone number used to call our customer support, social network decryptors which are used to communicate with our customer support service.
Processing is carried out in accordance with Article 6(1)(f) of the GDPR based on our legitimate interest in improving the stability and functionality of the PRANA platform and the investigation of complaints about a possible illegal use of the website.
6. PROCESSING OF CHILDREN'S PERSONAL DATA
PRANA does not deliberately collect or process information about users under the age of 16. If we become aware that we possess such information, we will take all reasonable steps to delete that information immediately.
7. PRANA GROUNDS AND PURPOSES FOR PROCESSING OF PERSONAL DATA
7.1. PRANA processes personal data provided by the users based on one or several purposes specified below:
• it is necessary for ensuring of PRANA service provision;
• it is necessary for expressing a commercial offer requested by the User with regard to services provided by PRANA;
• it is necessary for fulfilment of requirements of regulatory enactments;
• it is necessary for sending out PRANA’s commercial notifications, including those about novelties, discount campaigns, events, discounts, contests, lotteries or draws, or for tracking (profiling) of User’s shopping habits if it has been preceded by the separate and unambiguous consent of the User;
• it is necessary for the User’s participation in PRANA (user) loyalty programs;
• it is necessary for registration of the user on PRANA homepage;
• it is necessary for implementation or protection of legitimate (legal or contractual) interests of PRANA;
• it is necessary to provide the content on the PRANAs page to you and your computer in the most efficient way.
7.2. PRANA processes data obtained by the User visiting a PRANA website for the following purposes:
• to ensure continuous communication with PRANA;
• to ensure convenient use of PRANA and optimization of the platform;
• system monitoring and ensuring stability and security;
• to detect and prevent attacks on our website;
• PRANA's administration and internal operations, including troubleshooting, data analysis, testing, research, and other internal statistical and administrative purposes;
• analysis of advertising effectiveness.
PRANA processes customer data in accordance with its legitimate interests on the basis of Article 6(1)(f) of the GDPR. Our legitimate interests arise from the data collection objectives set out above.
8. TO WHOM PRANA MAY TRANSFER PERSONAL DATA
8.1. PRANA may transfer User’s personal data to the third parties only in cases if:
• you have specifically agreed to it as per Article 6(1)(f) of the GDPR;
• if it is necessary for implementation of legal obligations with regard to PRANA, as per Article 6(1)(f) of the GDPR;
• information dissemination is necessary to protect against claims or legitimate interests, and there is no reason to believe that your legitimate interests in not disseminating your personal data outweigh the interests of the controller under Article 6(1)(f) of the GDPR.
8.2. PRANA may transfer User’s personal data in certain cases:
8.2.1. if it is requested by state authorities or institutions authorized by them, courts, sworn advocates and bailiffs.
8.2.2. if it is necessary for ensuring the services provided by PRANA, as well as for implementation and protection of legal and contractual interests of PRANA, for example:
• to third persons whom PRANA has entrusted under the contract to perform certain functions or provide services necessary for provision of services and conducting or ensuring of activity by PRANA, including lawyers, accountants, communication, postal and information technology service providers, forwarding and delivery service providers;
• to debt collectors, administrators of bankruptcy or insolvency proceedings;
• performing audits related to existing interactions and parallel transactions, including performing calculation of ad impressions for unique visitors, checking the positioning and quality of ad serving, as well as checking compliance with a certain specification and other standards;
• detecting incidents related to security, protection against abusive, deceptive, fraudulent or other illegal activities, as well as prosecuting those responsible for these activities.
8.3. In the cases specified in Clause 7.2 of this Policy, PRANA provides or obtains from the third parties the User's personal data in the amount necessary for the provision of the respective service or performance of the respective activity.
8.4. Users' personal data specified in the personal profile when registering on the PRANAs platform is not reviewed with third parties
8.5. PRANA may also transfer the obtained information to:
• Analytics and search engine service providers which assist PRANA in improving and optimizing the operation of the website, provided that you have given your consent in the cookies section of this Policy (it does not identify you as an individual);
• if it were necessary for concluding an agreement with business partners on joint works for the provision of Services, with which PRANA entered into an agreement on joint responsibility for the processing of relevant personal data in accordance with Article 26 of the GDPR;
• a payment processing service provider that provides secure payment processing services. We draw your attention to the fact that Braintree does not transfer your payment card data to PRANA.
9. TRANSFER OF PERSONAL DATA OUTSIDE THE EUROPEAN UNION
9.1. For the processing of electronic payments PRANA uses the Montonio Finance payment service platform (www.montonio.lv).
If you select the parameter “Payment via bank” while placing an order, we will pass information on your order to Montonio Finance to perform the payment. Some of your messages will be stored in Montonio Finance payment processing system in case you need to process return of funds or provide support, as well as to prevent fraud.
Montonio Finance is a Lithuanian company, where an equivalent level of protection of physical person’s data is applied in the processing of personal data - the processing of data will be lawful and proportionate, the data will be secure, data subject's right to control his or her data will be respected.
For additional information, see https://montonio.com/lv/privatuma-politika/
9.2. We use Sendinblue services (https://www. sendinblue.com) to send messages.
Sendinblue is a French company that applies an equivalent level of personal data protection to the processing of personal data - the data processing will be lawful and proportionate, the data will be secure, the subject's right to control his data will be respected.
For additional information, see
10. HOW LONG PRANA KEEPS DATA
PRANA stores personal data as long as you have record entry with us to fulfill contractual obligations to you.
In addition, we store the data you voluntarily provide while using the PRANA website, unless you delete it earlier.
After deleting a record entry, PRANA processes the User's personal data for as long as it is necessary for a specific purpose to ensure the fulfillment of its obligations to the user and compliance with regulatory and commercial law, tax and other applicable law.
In addition, if permitted by law and there are no objections from the data subject, PRANA may store your personal data for a period of five years after the deletion of the record to detect any problems and resolve legal disputes.
We may also store shared information above a specified time for research purposes and to help develop and improve our Services. Please note that you cannot be identified by the shared information that is stored or used for these purposes.
11.1. What are cookies
Cookies are small text files kept by a website on your computer or mobile device when you open the website. It makes it possible for the website to remember your name and settings (for example, language, text sizes and other image settings), which you use to view this website in a way so that you do not have to do it again every time.
All cookies are depersonalized to the maximum and used only for improvement of homepage quality or for collection of statistic data.
- improve homepage functionality;
- customize homepage functionality in accordance with your user habits.
- obtain statistic data about the flow of homepage visitors: number of visitors, time spent on the website etc.
- to create an advertising strategy and show you more attractive advertising and offers.
11.3. Control over cookies and storage time
Cookies are kept on your computer or mobile device, and you fully control their use.
You can get acquainted with the kinds and types of cookies, their storage time and change the cookie settings by clicking on the "Cookie settings" button at the bottom of PRANA website. You may need to refresh the page for the settings to take effect.
You can also control the use of analytical, functional and marketing cookies by changing your browser settings.
Learn how to manage cookies in the most popular browsers:
11.4. Which cookies do we use?
• Required cookies
These cookies are necessary for you to freely visit and browse the website and use the features it offers, including obtaining information about the services and purchasing them. These cookies identify your device, but do not reveal your identity, nor do they collect or generalize information. Without these cookies, the website will not be able to function properly, such as providing you with the information you need, providing the requested services or logging in to the service or applying for the service. These cookies are stored on your device until you close your web browser.
• Functional cookies
With functional cookies, the website remembers the settings you have chosen and the choices you have made so that you can use the website more conveniently. These cookies are stored on your device permanently or temporarily.
• Analytical cookies
Analytical cookies collect information about how you use the website, find the most frequently visited sections, including the content you select when browsing the website. The information is used for analytical purposes to find out what interests users of the website and to improve the functionality of the website and make it more user-friendly. Analytical cookies only identify your device, but do not reveal your identity. In some cases, some of the analytical cookies are managed by third party data processors (operators), such as Google Adwords, on our behalf in accordance with our instructions and only for the stated purposes.
For information about cookie control in other browsers, we recommend visiting the browser developer's website.
To opt out of Google Analytics tracking in all browsers, we recommend visiting http://tools.google.com/dlpage/gaoptout
You can delete all cookies on your personal device, you can set them to block the insertion of cookies on your device
11.5. Third-party cookies
You can get acquainted with an additional information on these websites:
If you visit PRANA website with turned off cookies then, possibly, functionality of our services will be restricted.
12. SUBSCRIPTION TO OUR ADVERTISING NEWS AND ANNOUNCEMENTS
For its own legitimate interests and with your express consent in accordance with Article 6(1)(a) of the GDPR PRANA uses your e-mail address for marketing analysis and sending you advertising notices about PRANA's services.
If you subscribe to receive newsletters, we will retain your IP address provided by your Internet Service Provider (ISP), as well as the date and time of registration, so that you can later track any illegal use of your email.
You may opt out of using your email address at any time for marketing purposes by reviewing and updating your contact information in your record entry, or by clicking on the "Unsubscribe" link at the end of all our marketing and advertising communications.
13. INFORMATION PROTECTION
PRANA confirms that the information and personal data submitted by the User when placing an order or purchasing a product on the PRANA website will be processed and stored in accordance with the requirements of European Union normative enactments on personal data protection.
All personal data provided by the User is stored on our secure servers. All information will be encrypted using TLS.
By registering at PRANA website, you can gain access to your profile after entering a personal password. You are responsible for maintaining the confidentiality of this password. We ask you not to reveal this password to anyone and to close the browser window, having finished working on the PRANA website.
Unfortunately, information transmission on the Internet is not very secure. While PRANA makes every effort to protect your personal data, we cannot guarantee the security of your data transmitted to our platforms; any transfer of data will be at your own risk.
PRANA takes technical and organizational security measures to protect your data from unauthorized access, loss, destruction or alteration.
Our website may contain links to external websites. We are not responsible for the content or privacy policies of these websites.
14. WHAT ARE RIGHTS OF PRANA USER AS DATA SUBJECT
The User as data subject has the following rights with regard to processing of his or her personal data:
• the right to get an access to his or her personal data - the User has the right to get information, whether or not PRANA processes his or her personal data, and if processes data, the User may request an access to his or her personal data as well as full information on when, where, how and why his or her personal data has been stored and used;
• the right to make corrections to his or her personal data - the User has the right to ask to correct his or her personal data if it is inappropriate, incomplete or incorrect;
• the right to object to processing of personal data - the User has the right to submit objections due to processing of his or her personal data if the personal data use is based on marketing purposes;
• the right to withdraw the consent - the User has the right to withdraw his or her consent for processing of personal data. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
• the right to be forgotten - the User has the right to ask to delete its personal data if it does not contradict requirements of regulatory enactments;
• the right to lodge a complaint - the User has the right to lodge a complaint against processing of his or her personal data to PRANA and State Data Inspection if the User believes that processing of his or her personal data violates the User’s rights stated by regulatory enactments;
• other rights set out in the Regulation.
15. DELETION OF PERSONAL DATA
PRANA informs the User on the following: if the User deletes his or her profile from the PRANA platform, the following data shall continue to be stored about the User:
• invoices issued to and paid by the User will be stored in accounting within the term specified in the regulatory enactments;
• we retain all content that you publish publicly (such as public announcements, seller reviews, comments, etc.) for website management purposes.
After deletion of your profile, you will not be able to get access to it and it will not be able to restore it. Before deleting the profile, save data that is important for you.
16. WHERE PRANA USER MAY APPLY DUE TO PROCESSING OF PERSONAL DATA
Controller - Limited Liability Company „PRANA Ko”
Address: Spilves street 4, Riga, LV-1055, Latvia
E-mail: [email protected]
The User may apply to PRANA due to processing of personal data (on various issues, granting or withdrawal of the consent, use of its rights or with complaint against the use of its personal data as per the Article 21 of the GDPR) by sending his or her requests to the above mentioned address or e-mail address, specifying the subject of the message “Processing of personal data”.
Any subsequent changes to this Policy will be published by PRANA on this webpage and PRANA will notify its registered users of any material changes by e-mail notifications.
This Policy was last updated on May 10, 2022.