This Privacy Policy describes the personal data processing practices of Kole Systems s.r.o. (“Kole-Systems” or “we”, “us”, “our”). In this privacy notice you will find information on what personal data we process, how we process it and what rights you have regarding your personal data.
We at Kole Systems respect your privacy and process your personal data in accordance with the principles set out in the EU General Data Protection Regulation (Regulation 2016/679 EU, the “GDPR”).
CUSTOMER DATA
Where do we receive your data from?
We receive our customer data from our customers themselves when they place an order with us and when they make a contract with us. Typically, you would contact us and specify your personal details via email but you can also contact us and provide us with your personal data via our website’s contact form or by calling our customer service.
What do we collect?
We process only B2B customer data. This means that the personal data we process is related to you as a representative of your company, not as a private person. Unless you choose to provide us with your personal contact details, we will not process such information.
For processing your order, we need to collect your name, phone number, email, invoicing and delivery address, company name, as well as company ID and contact details (if different than delivery address), and of course, details of the products you have ordered. We need this information to process your order internally and delivering the ordered products to your location. We also need this information for invoicing and after that, bookkeeping and other mandatory administrative duties.
If you contact our customer service, we will process your above-mentioned customer details, as well as your message and our replies to you. If you are already our customer, we will link your inquiry with your existing customer profile. We do not record phone inquiries, but our customer support may write down a memo on the discussion or direct it internally to a suitable person to make sure your request is handled properly.
Sometimes we also receive feedback, complaints or claims from our customers. In such cases we need to collect the necessary customer details in order to link your complaint with your order, as well as a description of the defect or detriment in question and other details related to the complaint.
For what purposes do we process this data?
We need to process our customers’ personal data for:
- processing orders
- delivering purchased goods
- managing contracts with our customers
- invoicing
- providing customer service
- processing customer feedback, complaints and claims
- bookkeeping and accounting, and
- fulfilling other mandatory administrative tasks and safeguarding our legal rights
- improving our website and your shopping experience (we continually strive to improve our website offerings based on the information and feedback we receive from you)
- improve customer service
(your information helps us to respond to your customer service requests and support needs more effectively) - administrating a contest, special promotion, survey, activity or other site features.
How long do we store it?
We store orders placed by our customers for 3 years and the referrals to delivery partners for 1 year.
Contacts to our customer support and the following correspondence are stored for 3 years or for the duration of the customer relationship to us, whichever is longer. Customer claims and complaints, as well as all customer information and documents related to the claim or complaint, are stored for the period of the claim’s expiry defined by law and for the time required to process them.
Personal data entered into customer contracts are stored up to 10 years, unless the contract period is longer, in which case they will be stored until the end of the contract period and 3 years after the end of the contract period.
Invoices and other bookkeeping materials which may include personal data are held for 6-10 years in accordance with the relevant bookkeeping obligations.
SUPPLIER DATA
Where do we receive your data from?
We receive some personal data of our suppliers’ representatives directly from our suppliers when we enter into an agreement with them. The personal data content of our supplier relations is mostly limited to the contact person’s details of our suppliers. This can be entered into the supplier agreement or e.g. email correspondence between Kole Systems and its suppliers.
What do we collect?
We collect the supplier contact person’s name, email, company/office details and address.
Should you as a supplier’s representative contact our customer service or our offices otherwise, we will process your above-mentioned details, as well as your message and our replies to you. We may also link your inquiry with your existing details. We do not record phone inquiries, but our customer support may write down a memo on the discussion or direct it internally to a suitable person to be better able to make sure your request is handled properly.
For what purposes do we process this data?
We need to process our supplier representatives’ personal data for
- Managing supplier deliveries to Kole-Systems,
- managing contracts with our suppliers,
- invoicing,
- providing customer service,
- processing feedback and troubleshooting,
- bookkeeping and accounting, and
- fulfilling other mandatory administrative tasks and safeguarding our legal rights.
What are the legal bases for processing this data?
We mostly rely on our legitimate interest for maintaining our supplier relations for the purposes described above, as well as safeguarding our legal rights in the event of disputes.
There are also legal obligations we need to observe, e.g. with respect to bookkeeping and taxation for example, which may require us to process personal data to some extent.
How long do we store it?
Contacts to our customer support and the following correspondence are stored for 3 years or for the duration of your customer relationship to us, whichever is longer.
Personal data entered into supplier contracts are stored up to 10 years, unless the contract period is longer, in which case they will be stored until the end of the contract period and 3 years after the end of the contract period.
Invoices and other bookkeeping materials which may include personal data are held for 6-10 years in accordance with the relevant bookkeeping obligations.
WEBSITE VISITORS
Contact form
We provide our website visitors an opportunity to contact us directly via the contact form on our website. On the contact form you may provide us your name, email, company, country and the message of your choice.
In this context we also ask for your consent to send you electronic marketing. Please see more information on the personal data processing related to our marketing operations here.
The information provided by you via contact form may be combined with the other information we process related to you or your organization. Depending on the contents of the message, we may contact you for sales purposes or forward your message onwards to our customer support or to another unit or person within our organization.
Our purpose of offering you the option for contacting us via the form relates to customer service and sales. You may of course choose to contact us for another reason also. Our processing of the personal data provided via the contact form is based on our legitimate interest of providing customer service and promoting our products and services.
Downloads
We offer on our website certain materials to be downloaded by website visitors. When downloading materials, you may also provide us with your first name, last name, company details, email address and country.
In this context we also ask for your consent to send you electronic marketing. Please see more information on the personal data processing related to our marketing operations here.
Our purpose for processing your personal data in connection with offering free downloads is the promotion and marketing of our products and services. Our processing of the personal data provided via the downloads is based on our legitimate interest of promoting our products and contacting you for marketing purposes. Electronic direct marketing is based on your consent, which can be withdrawn by you anytime by unsubscribing from our mailing list.
We store your information for sales purposes for 5 years. For electronic marketing purposes, we will store your information for 1 year or until you cancel your subscription, whichever is longer.
MARKETING AND SALES
Email marketing
We may send you emails containing information regarding our products and services. Marketing emails can be sent to our customers and suppliers, business contacts we deem interested in our products and services due to their work tasks, as well as those who have subscribed to our email lists.
We may receive your contact details directly form you, our commercial partners or social media and other public sources.
For email marketing purposes we process your name, email address, your position in your company and your status related to us (e.g. customer contact person / prospective customer), as well as the contents of the communications we have sent to you.
If you are a business contact, our email marketing may be based on our legitimate interest to promote our products and services. If you have subscribed to our emails, our processing of your personal data for email marketing purposes is based on your consent, which can be withdrawn by you anytime by unsubscribing from our mailing list. For electronic marketing purposes, we will store your information for 1 year or until you cancel your subscription, whichever is longer.
Who do we disclose your personal data to or share your personal data with?
Controller to processor disclosures
We rely on digital services provided by external service providers when processing personal data in our operations. Such services are subcontracted in terms of the GDPR and include e.g. email, data storage, website hosting, digital co-working space, email marketing platform, customer support tickets, etc. These services are governed by separate service agreements between us and the service provider, and we remain responsible for the personal data processed through them as data controllers.
Controller to controller disclosures
When delivering goods to you, we will share your delivery details with 3rd party delivery partner determined by you in connection with placing your order with us. When delivering goods abroad we will also need to disclose the personal data included in the order to the customs of the destination country. Sharing of your delivery details is based on our legitimate interest of delivering the ordered goods to you and fulfilling the contract between us.
In case of non-performance of payment obligations by customer, we will share the details necessary for the collection of the outstanding payments to an external collection agency. The sharing of your data is based on our legitimate interest to execute our agreement and to safeguard our rights.
The abovementioned external parties will apply their own privacy policies to the processing of personal data.
Your rights as a data subject
Data subjects have the following rights under the GDPR:
Right to access your information: You have the right to know what information we have and process about you and may request us to provide you access to this data.
Right to rectification: You have the right to request incorrect or incomplete information about you to be rectified.
Right to erasure or restriction: You have the right to request your data to be erased when the processing of your personal
data is no longer necessary and in certain other situations provided for in the GDPR. If we have a right to deny your demand of erasure, or if the retention of your personal data is necessary for the investigation of your claim otherwise, you have the right to require for the restriction of its processing from us.
Right to objection and right to withdraw consent: you have the right to object to the use of your personal data for profiling and direct marketing, as well as processing of your personal data when it is based on our legitimate interest. If our processing of your personal data is based on your consent, you have the right at any time to withdraw such consent.
You may object to our email marketing or withdraw your consent by clicking the unsubscribe-link provided at the bottom of each email communication.
With respect to sales contacts, you may object to the processing of your personal data and ask us not to contact you again.
Right to data portability: If our data processing is based on your consent or a contract between us, you have the right to receive a copy of the personal data you have provided to us yourself in a structured machine-readable format.
Right to lodge a complaint with the supervisory authority: Finally, if you feel that your rights have not been respected in connection with our data processing procedures, you do have the right to lodge a complaint with the national supervisory authority. However, before doing so we would kindly ask you to contact us and voice your concern so that we may try to find a solution together.
Updates
This Privacy Policy may be periodically updated. We encourage you to review it regularly for the latest information.
Contact Us
For any inquiries about this Privacy Policy, please contact us via e-mail:
info@kole-systems.com