Personal Data Policy
Lenoites AB, organization number 556998-1755, Stormgatan 3, 504 64 Borås, Sweden ("Lenoites") processes personal data in accordance with applicable law, including the EU General Data Protection Regulation (GDPR).
The terms "we," "our," "us," and "ours" as used below refer to Lenoites.
1. DATA PROTECTION OFFICER
Lenoites has appointed a Data Protection Officer (DPO). Among other tasks, the DPO is responsible for overseeing that Lenoites' processing of personal data complies with current legislation. To obtain contact details, please email lenoites@lenoites.com.
2. PERSONAL DATA PROCESSED
The information processed includes personal data that you provide to us, that we collect from you, and that we receive about you from others. Personal data you provide to us, such as when you make a purchase, sign up for our newsletter, register a user account, take out insurance, use the services on our site, our social media, or exercise your rights under consumer legislation, include details like your name, address, personal identification number, mobile and telephone number, and email address.
Personal data we collect from you include details when you make a purchase at Lenoites, when you contact us, and when you use our site, your user account, or social media (Facebook, Instagram). Such information comprises your name, date of birth, gender, contact details, customer data, IP address, operating system, information about the hardware and software you use, browser settings, time zone, data collected from cookies, details related to your contacts with us including recorded audio files, information about your browsing habits (such as geographic location, session duration, which external pages you have previously visited, which pages and social networks you visit with us, your interests, and information about your other use of our services and products), search and purchase history, order numbers, which items you have visited or added to our shopping cart, payment methods and account balance, and if you have purchased your item on credit, payment information, as well as your activity on our pages, social networks, and our site. Personal data about you that we receive from others may include emails and other correspondence containing personal data about third parties, which Lenoites will therefore process. If necessary, Lenoites will inform you as a third party about the processing.
3.
WHY AND ON WHAT LEGAL BASIS DO WE PROCESS YOUR PERSONAL DATA?
For Customer Service and Customer Relationship Management
We process names, addresses, personal identification numbers, mobile and telephone numbers, email addresses, purchase history, order numbers, payment information, and recorded audio files from your contact with us in order to provide you with good customer service and to manage our customer relationship with you. We will process your personal identification number in case you choose to use it to retrieve your address details. The legal basis for our processing of your personal data is that it is necessary for us to fulfill our contract with you or to take measures prior to entering into a contract, or alternatively, our legitimate interest in providing good service in case you are not a customer with us. Our interest in processing your personal data for this purpose takes precedence over any potential interest you have in protecting your personal privacy.
If you do not provide the aforementioned personal data, we will not be able to deliver our products to you or otherwise fulfill our commitments towards you.
For Credit Provision We process information about you and your purchase to enable you to make purchases on credit. For this reason, we will process your customer number, purchase history, credit information such as your granted credit, and your personal identification number. The legal basis for our processing of your personal data is that it is necessary for us to fulfill our contract with you.
For Marketing We process names, mobile and telephone numbers, email addresses, your activity on our pages, your purchase history, order numbers, data collected from cookies, and information about your use of social media to send newsletters and promotional offers, as well as reminders about items left in your shopping cart to you via email, SMS, "push notifications," or mail. The legal basis for our processing of your personal data when we send newsletters to you is your consent, which we either obtain when you register as a user with Lenoites or in connection with your purchase of products from our assortment. You give your consent by actively checking one or more boxes on our site. You can withdraw your consent in the same way by unchecking the boxes on our site. When we process your personal data to send "push notifications" with marketing to you, the legal basis is consent. You give your consent by enabling "push notifications" on your mobile phone and withdraw your consent by disabling "push notifications" on your mobile phone. The legal basis for our processing of your personal data when we send promotional offers and reminders about items left in your shopping cart to you is based on a balancing of interests. The processing is necessary for our legitimate interest in marketing our products. Our interest in processing your personal data for the said purpose outweighs your potential interest in protecting your personal privacy. We also use Google in our marketing; you can read more about their data handling policies here.
For Automated Decision-Making or Profiling
In order to develop our products, services, and offers for you, we may automatically collect and analyze information about you. Such information includes your name, date of birth, gender, contact details, customer information, IP address, operating system, information about the hardware and software you use, browser settings, time zone, details related to your contacts with us, information about your browsing habits, search and purchase history, order numbers, which items you have visited or placed in our shopping cart, payment methods and account balance, and whether you have purchased your item on credit, as well as your other activities on our pages, data collected from cookies, social networks, and our site. Based on the results of this analysis of your user behavior (known as profiling), we then automatically provide you with customized information in the form of advertisements and offers that we believe you will find interesting and relevant. Currently, there is no automated decision-making or profiling that would affect you legally or significantly in any other way. The legal basis for our processing of your personal data is a balancing of interests. The processing is necessary for our legitimate interest in developing our business and, as far as possible, to avoid unnecessarily disturbing you and to provide you with materials, invitations, and offers that match your preferences and needs. Our interest in processing your personal data for this purpose takes precedence over your potential interest in protecting your personal privacy.
For Statistics
We process your customer number and other reference numbers for the purpose of compiling statistics. The legal basis for our processing of your personal data is our legitimate interest in maintaining statistics and thereby developing our business. Our interest in processing your personal data for this purpose therefore outweighs any potential interest you have in protecting your personal privacy.
For Handling Complaints, Returns, etc.
We process names, addresses, mobile and telephone numbers, email addresses, and purchase history in order to manage any requests you may have to return products or to exercise your consumer rights to claim for defects and delays against us. The legal basis for our processing of your personal data is that it is necessary to fulfill legal obligations incumbent upon us according to consumer legislation.
For Accounting
We process information about the transaction that has occurred between you and Lenoites for accounting purposes. We process information about the purchase, names, addresses, mobile and telephone numbers, and email addresses. The legal basis for our processing of your personal data is that it is necessary to fulfill a legal obligation incumbent upon us.
4. TO WHOM DO WE DISCLOSE PERSONAL DATA, AND WHERE DO WE PROCESS IT GEOGRAPHICALLY?
Your personal data may be disclosed to and processed by companies within the Lenoites Group.
Lenoites may also disclose your personal data to third parties. Examples of third parties to whom we may disclose your personal data include logistics companies in connection with the delivery of goods, media agencies for the distribution of newsletters, marketing partners, credit reporting or debt collection agencies for credit checks, and law firms for handling legal matters in our operations. If you make a purchase on credit, we may also disclose your personal data to Resurs Bank AB. If you purchase a product that includes insurance, we will disclose your personal data to the relevant insurance provider. All these entities are independently responsible for their processing of your personal data.
Lenoites may disclose your personal data to service providers and partners who process personal data on our behalf, known as data processors. We have agreements with our data processors that ensure they process your personal data in accordance with this privacy policy and our instructions.
Lenoites may disclose your personal data to authorities that require Lenoites to disclose such information. Lenoites may also disclose your personal data to allow for a merger, acquisition, or sale of all or part of Lenoites' assets.
As a general rule, Lenoites processes your personal data only within the EU and EEA. Should personal data be processed outside of the EU and EEA, we ensure that your data is protected in a manner equivalent to the protection offered within the EU/EEA by using standard contractual clauses that we have entered into with these entities or other appropriate security measures. A copy of the standard contractual clauses can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.
5. HOW LONG DO WE PROCESS THE PERSONAL DATA?
We only process personal data for as long as necessary for the purposes for which the data was provided or collected. The same personal data may be stored in multiple locations for different purposes. This means that a piece of data that has been removed from one system because it is no longer necessary for that purpose may remain in another system for another purpose where the personal data is still required.
Personal data that we process for customer service and to manage your customer relationship are processed for the time necessary for us to fulfill our contract with you or as long as we have a legitimate interest in processing the data. Recorded conversations with you are processed for three months.
Personal data that we process to enable credit provision are processed for the time necessary for us to fulfill our contract with you.
Personal data that we process for marketing in the form of newsletters and "push notifications" are processed until you withdraw your consent, unsubscribe, or otherwise ask us to stop contacting you. In connection with this, to the extent possible, we will also erase the personal data we process about you related to automated decision-making and/or profiling. Personal data that we process for marketing purposes other than newsletters and "push notifications" are processed during the customer relationship and for one year thereafter.
Personal data that we process for the purpose of statistics are processed until the relevant accounting material has been deleted, specifically for seven years.
Personal data that we process to fulfill our legal obligations to you, such as fulfilling warranty, complaint, or right of withdrawal commitments, are processed for the period that we have these legal obligations according to law.
Personal data that we process for accounting purposes are processed for seven years in accordance with applicable accounting legislation. Your personal data may be stored for longer than stated above if necessary to comply with legal requirements, regulations, or governmental decisions.
6. YOUR RIGHTS
When we process your personal data, you have certain rights under the law. Please note that the exercise of these rights is subject to certain requirements and conditions as set out in the law (EU General Data Protection Regulation). Right to information, access, rectification, erasure, restriction, etc. You have the right to request, in writing and without charge, information about the personal data we process about you. You can request corrections of inaccurate data at any time and you may also have the right to ask us to erase the personal data we have registered about you and to request a copy of your personal data. You may also have the right to request that processing be restricted. For example, you may have the right to restriction if you have objected to our processing of your personal data, or if you have requested rectification and wish to restrict our use while we verify whether the data is accurate. If you do not have grounds for your request or if your request is unreasonable, for instance, if you request access or erasure frequently and at short intervals, we have the right to refuse to comply with your request or to charge a fee that covers the administrative costs your request incurs.
Right to Data Portability
You may have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format and have the right to transmit those data to another data controller. Right to Object to Direct Marketing You may object at any time to the processing of your personal data for direct marketing or profiling for such purposes. If you do not want us to process your personal data for this/these purpose(s), please inform us by contacting us using the contact details provided below, see section 7. We will then cease processing your personal data for this/these purpose(s) and remove the data, provided we do not need to continue processing them for another purpose in accordance with this privacy policy. Right to Lodge a Complaint If you are dissatisfied with how we have processed your personal data, you can also contact us using the contact details according to section 7 below. You also have the right to submit a complaint regarding our processing of your personal data to:
The Swedish Authority for Privacy Protection Box 8114
104 20 Stockholm
imy@imy.se
If your complaint only relates to a company in another EU member state, you have the right to submit your complaint to the relevant data protection authority in that country. Here is a list of data protection authorities in other countries: https://edpb.europa.eu/about-edpb/about-edpb/members_en
7. CONTACT US
You can contact us in the following ways:
- via email: lenoites@lenoites.com
- by writing to Lenoites, Stormgatan 3, 504 64 Borås, Sweden
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