This policy is part of the Customer agreement, hereinafter referred to as the "Agreement", accepting the terms of which (by accepting the offer), you give your consent to the processing of your personal data on the terms set forth in the Privacy policy set out below.
LetyShops acts as the processor of Your personal data.
We act both as the controller and the processor of Your personal data in the sense attached to these terms in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, which repeals Directive 95/46/EC.
The contact details for the LetyShops data protection officer and other representatives of LetyShops are given in Section 11 of this Privacy Policy.
LetyShops may use Your personal data for the following purposes:
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2.1
Identification for entering into and execution of the Agreement with You (hereinafter referred to as the "Identification for Registration");
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2.2
Execution of the terms of the Agreement with You (hereinafter referred to as the "Agreement Execution"), including the following activities necessary to do so:
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(a)
Promotion of the products and/or services of the Advertisers with the description of cashback, which You may have received for the purchase of goods from the relevant Advertisers (hereinafter referred to as the "Promotion under the Agreement");
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(b)
The implementation of the referral programme.
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(c)
Promotion of LetyShops services, including informing about LetyShops new products, as well as promos, drawings, discounts, etc. on the letyshops.com websites, among other things, about the conditions of the referral or affiliate programmes, loyalty programmes, Premium, Lety Gold, Lety Silver, Lety Bronze accounts, and Lety codes (hereinafter referred to as the "Promotion of the LetyShops Service");
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(d)
Development, improvement, modernisation, updating of services and products of LetyShops (hereinafter referred to as the "Service Improvement");
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(e)
Informing You in connexion with the Agreement, among other things, on the updates of LetyShops services (hereinafter referred to as the "Informing under the Agreemen");
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2.3
Payment of cashback to You in full compliance with the applicable law and the requirements of the payment systems You have chosen to withdraw cashback (hereinafter referred to as the "Cashback Payment");
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2.4
Direct marketing, advertising, and promotion of products and/or services of LetyShops partners (hereinafter referred to as the "Direct Marketing");
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2.5
Analysis of the consumer market taking into account Your personal data and using the LetyShops service for marketing of services of LetyShops (hereinafter referred to as the "Market Analysis for LetyShops Marketing");
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2.6
Compliance with the requirements of the applicable law or the decision of a court or other competent state or municipal authority (hereinafter referred to as the Compliance with the Requirements of the Law or the Decision of the Competent Authority).
Please note that the terms in brackets will be used hereinafter in their full meaning as defined in this paragraph 2 of the Privacy Policy.
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3.1
The Customer is solely responsible for updating and maintaining the correct contact information in his/her account on the Service. The Customer can make all the changes necessary on the Settings page in his/her personal account on LetyShops.
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3.2
The information You provide us with:
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(a)
When registering with LetyShops via email:
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(i)
Your name (nickname) on the letyshops.com website.
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(ii)
Your password for Your personal account.
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(iii)
Your email address.
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(iv)
Your place of residence.
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(v)
Currency used.
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(vi)
Your profile picture.
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(b)
When registering with LetyShops through social media:
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(vii)
The ID of Your Facebook profile or Your Google account.
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(viii)
Your email address.
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(ix)
Your Facebook profile photo or Your Google account photo.
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(x)
Your state of residence.
The above personal data are hereinafter referred to as the "Identification Information".
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(c)
In Your personal account after Your registration (on Your initiative):
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(xi)
Date of birth.
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(xii)
Phone number.
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(xiii)
Gender.
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(xiv)
Your Service profile photo.
The above personal data are hereinafter referred to as the "Additional Identification Information";
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(d)
For cashback payments, depending on the requirements of the applicable law and the payment systems:
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(xv)
Phone number (if withdrawal is made by replenishment of the subscriber’s account).
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(xvi)
Your credit card or account number (wallet in the payment system) the cashback is paid to.
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(xvii)
Your name and surname (when making the Cashback Payment using Visa, MasterCard, PayPal, etc. payment systems).
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(xviii)
Your physical address.
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(xix)
Other information necessary to make the Cashback Payment in accordance with the requirements of the applicable law and the payment systems.
The above personal data are hereinafter referred to as the "Transfer Details".
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3.3
The information we receive from other sources:
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(a)
Regardless of the method of processing personal data, except for Identification for Registration:
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(i)
Your identification number (ID) in the LetyShops service, assigned after registration.
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(ii)
Your IP address.
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(iii)
Your geolocation, using GPS and public Wi-Fi networks.
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(iv)
Identifiers (UUID, model, and others) of Your computer, mobile device, or tablet.
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(v)
Your operating system and its version.
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(vi)
Type and version of Your browser.
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(vii)
Version and identifiers of the LetyShops mobile application that You use.
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(viii)
Time zone.
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(ix)
Language used.
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(x)
Detailed information about your activities on letyshops.com website, including the time spent on their web pages, clicks on the links (click-throughs) hosted on these websites, movements of the cursor or other pointer across the web pages of the above websites, scrollings through the content of the web pages of the above websites.
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(xi)
Cookies (small files stored in the memory of Your device, designed to personalise Your activity and behaviour on letyshops.com website, and other websites).
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(xii)
Your browser cache (files stored in the memory of Your device, which reproduce some parts of the web pages You have visited on letyshops.com website and allow reducing the time of loading of the content of these web pages).
The above information is hereinafter referred to as the "Standard External Information";
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(b)
Additionally, when Executing the Agreement with You:
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(xiii)
Information from the Advertisers about Your purchases of their products and/or services.
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(xiv)
information about your Gmail contacts if you are using Gmail Sharing;
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(c)
Additionally, at the Cashback Payment:
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(xv)
Information from payment systems, banks, communications providers, and other intermediaries participating in the Cashback Payment.
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(d)
Additionally, for the Compliance with the Requirements of the Law or the Decision of the Competent Authority:
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(xvi)
Any information necessary for Compliance with the Requirements of the Law or the Decision of the Competent Authority.
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The way we use Your personal data depends on the specific purposes for processing it. Note that the terms denoting the purposes for processing are hereinafter used in their full meaning given in paragraph 2 of the Privacy Policy.
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4.1
Use of personal data for Identification for Registration
In order to individualise You as a party to the Agreement, we must obtain sufficient information to establish Your identity. So we have provided the registration procedure with the Service.
For You to register successfully, You need to provide us with Your Identification Information (listed in paragraphs 3.2(a) and 3.2(b) of the Privacy Policy).
Thus, we collect, record, and systematise Your Identification Information, through automated means as well. We can also specify this information to make sure that Your Identification Information is accurate and up-to-date.
We store Your Identification Information until the termination of the Agreement (deletion/blocking of Your account). After that, Your Identification Information is deleted and destroyed.
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4.2
Use of personal data in the Agreement Execution
For all the means necessary for the fullest and most qualitative Agreement Execution, including for the Promotion under the Agreement, the implementation of the referral programme, the Promotion of the LetyShops Service, the Service Improvement, and Informing under the Agreement, we process the following information:
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(a)
Your Identification Information (listed in paragraphs 3.2(a) and 3.2(b) of the Privacy Policy).
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(b)
Your Additional Identification Information (listed in paragraph 3.2(c) of the Privacy Policy).
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(c)
Standard External Information (specified in paragraph 3.3(a) of the Privacy Policy).
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(d)
Information from the Advertisers about Your purchasing of their products and/or services after You use the LetyShops service.
Using automated processing of the aforementioned data, we form derived data about Your preferences that we also use for a full and qualitative Agreement Execution, among other things, for Service Improvement, Promotion under the Agreement, and the Promotion of the LetyShops Services.
The benefit to You is that we may draw Your attention to the offers from Advertisers that are likely to interest You, arising from Your activities on the letyshops.com website (for example, if You have made orders in stores for household appliances or clothes, we may draw Your attention to other offers in this area). We can also customise the Promotion of the LetyShops Services for You so that You become more likely to receive information of interest to You.
We carry out the Promotion of the LetyShops Services for our existing and potential Customers to receive full information about the services we provide, about new LetyShops products, and to more actively use our service, gaining additional benefits from using the LetyShops Service.
Among other things, we:
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(e)
Collect, record, systematise, accumulate, and use the personal data listed above.
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(f)
Share them with the advertising platforms and services, CPA and CPI partner networks LetyShops cooperates with on the basis of contracts and agreements, the implementation of which is necessary or predetermining to the signing and execution of the Agreement with You and other Customers, among other things, for LetyShops to receive the Commission.
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(g)
Use them to send You notifications by sending them to Your personal account and to Your email address, which include:
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(i)
Letters on cashback crediting, changes in the balance, finances, and orders.
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(ii)
Letters on introductions to the Service or on the new version of the Agreement available.
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(iii)
Letters about new promos, drawings, and other events and programmes encouraging You to use the LetyShops Service.
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(iv)
Other service and informational letters.
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(h)
Use of personal data for our "Refer & Earn" Referral Program:
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(v)
If you have registered at LetyShops using URL link provided to you by another LetyShops user (hereinafter referred to as the "Referrer") within the frames of our "Refer & Earn" Referral Program, we transfer to the Referrer the data of your LetyShops account (full name/nickname, ID, profile picture) as well as details of your orders such as order date, amount, the partner shop title, cashback amount, ongoing cashback status and other similar statistical information without disclosing to the Referrer the information about specific products ordered by you.
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(vi)
If you use Gmail Sharing to invite new users to LetyShops within the frames of our "Refer & Earn" Referral Program, we receive the list of your Gmail contacts in the encrypted form with the purpose of sending to such contacts our standard "Refer & Earn" Referral Program welcome mail containing your referral link.
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We store the above personal data until the termination of the Agreement between You and LetyShops (deletion/blocking of Your account). After that, Your data is deleted and destroyed.
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4.3
Use of personal data for Cashback Payment
To ensure the Cashback Payment, we need to know the methods and details to use to transfer the funds and to be able to check the status of the payment execution.
For this purpose, we obtain:
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(a)
From You—Cashback Transfer Details (indicated in paragraph 3.2(d) of the Privacy Policy).
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(b)
From payment system operators, banks, communications providers, and other intermediaries participating in the Cashback Payment—the information on the possibility, reception, and status of the payment execution.
We collect, record, systematise, accumulate, and use the above information in the processing of payment records and transferring cashback to You.
We store the above personal data until the termination of the Agreement between You and LetyShops (deletion/blocking of Your account). After that, Your above-mentioned data is deleted and destroyed.
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4.4
Use of personal data for Direct Marketing
We use Direct Marketing for commercial purposes, for You to have the possibility to obtain information about the products and/or services of our partners that may be of interest to You.
To carry out the Direct Marketing, we collect, record, systematise, accumulate, and use:
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(a)
Your Identification Information (listed in paragraphs 3.2(a) and 3.2(b) of the Privacy Policy), except for Your password to Your personal account.
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(b)
Your Additional Identification Information (listed in paragraph 3.2(c) of the Privacy Policy).
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(c)
The information specified in paragraphs 3.3(a)(ii), 3.3(a)(x) and 3.3(a)(xi) of the Privacy Policy,
as well as the results of the automated processing of the above information.
The benefit of such automated processing for You is that we are attempting to determine the probable effectiveness of the Direct Marketing.
We may also share the above information with our partners, with whom LetyShops has entered into an appropriate agreement on advertising, promotion, or marketing (including through intermediaries), and we may use various marketing, statistical, and technical tools. For the avoidance of doubt, by agreeing to the processing of Your data for the purposes of Direct Marketing, You confirm that You have read and agree to the processing of Your data during the use of these tools, namely:
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(d)
Facebook Pixel. Data usage policy published at https://www.facebook.com/about/privacy;
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(e)
Google Analytics. Google Analytics Terms of Use, published at the following URL, where you can select the language in which to read the document: https://www.google.com/analytics/terms;
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(f)
Hotjar. Data usage policy published at https://www.hotjar.com/legal/policies/privacy;
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(g)
Google Ads. Google Ads Terms of Use, published at the following URL, where you can select the language in which to read the document: https://policies.google.com/technologies/ads
We store the above personal data until the termination of the Agreement between You and LetyShops (deletion/blocking of Your account).After that, the above data at the disposal of LetyShops is deleted and destroyed.
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4.5
Use of personal data in the Market Analysis for LetyShops Marketing
We carry out the Market Analysis for LetyShops Marketing, taking into account the behaviour and preferences of LetyShops customers. Marketing promotes the growth of LetyShops business, which may subsequently contribute to improving the quality of our services.
To implement the Market Analysis for LetyShops Marketing, we collect, record, systematise, accumulate, and use:
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(a)
Your Identification Information (listed in paragraphs 3.2(a) and 3.2(b) of the Agreement), except for Your password to Your personal account.
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(b)
Your Additional Identification Information (listed in paragraph 3.2(c) of the Agreement).
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(c)
Standard External Information (specified in paragraph 3.3(a) of the Agreement),
as well as the results of the automated analysis and other processing of the above information.
We may also share the above information with our partners, with whom LetyShops has entered into an appropriate agreement on analytics, statistical research, and so on (including through intermediaries).
Such automated processing allows us to carry out the market analysis and obtain relevant results, as well as to structure them by customer categories depending on various criteria(for example, the state of residence). Thus, Your data becomes part of the results of the Market Analysis for LetyShops Marketing.
We take into account the above data when developing our market strategy, as well as the services and products of LetyShops.
We store the above personal data until the termination of the Agreement between You and LetyShops (deletion/blocking of Your account). After that, the above data at the disposal of LetyShops is deleted and destroyed, and the analysis results are depersonalised (if they had not been earlier).
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Please note that in the cases described in paragraph 4, your data can be transferred to states with a level of privacy regulation that does not meet high standards. For example, data may be transferred to states, the level of protection of personal data in which has not been determined by the european commission to be adequate to the regulation in the european union.
In this case, the probability of the leaking of your personal data and failure to handle it within a reasonable time increases significantly. Your personal data may be disclosed, and abusive individuals may use them without your consent.
By giving consent to your data processing in accordance with the agreement and privacy policy, you expressly confirm that you are fully aware of and accept the above risks.
By giving your consent to processing your data for direct marketing, you expressly confirm that you are fully aware of and accept the above risks.
We, in turn, take measures to minimise these risks for you by including (to the extent possible) provisions in the contracts and agreements with the recipients of your data that comply with standard contractual terms approved by the european commission.
We use Your personal data on legal grounds. Therefore, we process Your personal data only if:
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6.1
You have given Your consent to process Your personal data in one way or another as provided for in the Agreement.
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6.2
The processing of Your personal data is necessary for the execution of the Agreement.
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6.3
We must process Your data in accordance with the requirements of the applicable law, a decision of a court or other competent state or municipal authority.
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6.4
You have made such data publicly available and accessible.
LetyShops provides recording, systematisation, accumulation, storage, improvement (updating, modification), extraction of Your personal data using databases located on the territory of the Germany.
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7.1
Germany if you are a citizen of any of the member states of the European Union.
We take technical, organisational, and legal steps, or ensure that they are taken, to protect Your personal data against unauthorised or accidental access, collection, storage, use, transmission, blocking, or destruction, as well as from other illegal acts or accidental leaks.
For example, we provide the following:
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8.1
Appointment of data protection officers.
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8.2
Restriction and regulation of the staff of LetyShops, who have access to personal data.
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8.3
Introduction of the requirements of the applicable law and regulations on the processing and protection of personal data to the employees of LetyShops.
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8.4
Accounting and storage of physical storage media and their circulation, which precludes theft, substitution, unauthorised copying, and destruction of information.
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8.5
Identification of threats to the security of the confidentiality of personal data during processing, and the formation of threat models based on this identification.
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8.6
Development of the personal data protection system on the basis of the threat model for the corresponding class of information systems.
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8.7
Inspection of the preparedness and effectiveness of the use of information security tools.
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8.8
Implementation of a licensing system for access to information resources, software and hardware for processing and protection of information.
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8.9
Ascertaining and recording of the actions of personal data information system users.
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8.10
Password protection of users’ access to the personal data information system.
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8.11
Application of access control to communication ports, information input-output devices, removable media, and external storage devices.
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8.12
Implementation of anti-virus control, prevention of penetration of malware (software viruses) and software bugs into the corporate network.
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8.13
Detection of intrusions into the corporate network of LetyShops, which violate or create the preconditions for violation of the established requirements for the security of personal data.
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8.14
Integrated management of the personal data protection system.
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8.15
Training employees using information security tools used in personal data information systems to work with them properly.
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8.16
Accounting for the information protection tools applied and the operational and hardware documentation for them.
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8.17
Monitoring of user actions,investigation of violations of the requirements for the security of personal data.
We respect Your personal data rights and do what we can to ensure their realisation.
You can contact our data protection officer with a request for the realisation of Your rights listed below (see contacts in Section 11 of the Privacy Policy).
We ensure the execution of the request within a reasonable time, but not later than 1 (one) month from the receipt of the request.
This period can be increased to 3 (three) months in the case of the complexity of a request or a large number of requests from LetyShops customers. We shall notify you in advance about such an extension of the term using the email address You specified when registering.
Upon Your request, addressed to us, you can realise Your rights for:
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9.1
Access to information related to the processing of Your personal data:
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(a)
Access to information falling within the scope of this Privacy Policy.
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(b)
Obtaining an electronic copy of all processed personal data in a structured form and computer-readable format.
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9.2
Clarification of Your personal data, upon which we notify thereof all persons we previously shared Your personal data with, provided that such notification is not impossible or does not demand disproportionate efforts on our part.
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9.3
Direct transfer of Your personal data from LetyShops to third parties.
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9.4
Restriction or full or partial withdrawal of Your consent to the processing of Your personal data in one way or another.
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9.5
Destruction of Your personal data (we shall notify all personal data processors we have shared Your data with, provided that such notification is not impossible or does not demand disproportionate efforts on our part):
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(a)
At Your request.
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(b)
If Your consent to processing is withdrawn.
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(c)
If the need for processing Your personal data is no longer relevant.
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9.6
You can delete your LetyShops account at any time you want. From this moment we stop processing your personal data which were being processed previously on the basis of legal interest (executing our Terms of Use) and erase all your data collected without the possibility of recovering.
For deleting your LetyShops account:
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•
Log in to your account using username and password.
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•
Go to "Settings" and choose "General settings".
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•
Scroll to the bottom of the page.
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•
Click on "Delete your account".
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•
Choose "Permanently delete" on the next page.
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•
Specify the reason for deletion (optional).
Please note, that you remain to be able to create a new LetyShops account but all the previous information and the cashback balance will be lost.
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If You believe that Your rights and/or legitimate interests have been violated, You have the right to file a claim or complaint with the competent state authority. For example, if You are in the territory of the European Union, You have the right to file a complaint with the supervisory authority of the relevant member state of the European Union.
If You believe that the automated processing of Your personal data violates Your rights and/or interests, or creates significant negative consequences for You, we shall ensure human intervention in the results of the automated processing and shall ensure Your right to challenge the decisions taken with the help of automation tools.
Also, apart from the above information, we emphasise that You, among other things, can refuse to process Your personal data for the purposes of Direct Marketing. In doing so, we shall ensure that such processing is terminated and Your personal data is removed. The information contained in this paragraph does not in any way limit Your right to withdraw consent to other types of processing of Your personal data.
This Privacy Policy determines only how Your personal data is processed by LetyShops, not by anyone else.
The processing of Your personal data by other individuals, for example, when you follow the links to the websites of the Advertisers, is not regulated by this Privacy Policy, unless specific exceptions to this rule are expressly indicated in the Agreement and Privacy Policy.
You can contact us or send Your questions to us using the Help section.
The Company also operates the hotline on the phone numbers specified on the site.
You can contact our data protection officer on issues related to the processing of Your personal data:
Address: 2161 Csomád, Akácos utca 15, Hungary.
Email address: dpo@letyshops.com
Contact details for our authorised representative in the European Union:
Address: 2161 Csomád, Akácos utca 15, Hungary.
Email address: dpo@letyshops.com
LetyShops KFT Company, drawn up in accordance with the laws of Hungary under company registration number 13-09-200084, registered at:2161 Csomád, Akácos utca 15, Hungary.