This document is effective from May 25, 2018.
Senetic Limited, Senetic.ng, we, our - Senetic Limited with its registered office in 7th Floor, Mulliner Towers, 39 Alfred Rewane Road, Ikoyi, Lagos, Nigeria
Customer - a Consumer or an Entrepreneur who has placed or intends to place an Order or uses other services of the Online Shop (hereinafter also referred to as the "Buyer").
Consumer - a natural person who performs a legal activity not related directly to its business or professional activity.
Entrepreneur - a natural person, a legal person or an organizational unit, which by law has a legal capacity, undertaking activities for purposes directly related to its business or professional activity.
Customer Account (Account) - a subpage of the Shop, where the Customer can, among others, manage personal data, receive notifications about change in the status of the Order and control and manage the status of placed orders.
Online Shop Senetic.ng(hereinafter also referred to as "Shop" or "Online Shop") - an internet service available at http://www.senetic.ng, through which the Service Provider provides the services specified in the Terms and Conditions and the Customer may place Orders.
Terms and Conditions - Terms and Conditions of sale by means of distance communication and providing services by electronic means by the online shop Senetic.ng.
Goods - a material movable item being the subject of a Sales Contract or a right being the subject of a Sales Contract (e.g. a license).
Service (Services) - Order, License Order or Offer inquiry, as well as other services provided by the Shop.
Order - Customer′s declaration of will constituting an offer to conclude a Sales contract with Senetic Limited, aiming directly to conclude a Distance Selling Contract via the Online Shop specifying the type and number of Goods being the subject of the Sales Contract.
License order - Customer′s declaration of will constituting an offer to conclude a contract with Senetic Limited for a software license, aimed directly to conclude a Distance Selling Contract (sale of licenses) via the Online Shop, specifying the type and number of software for the use of which the license is sold.
Offer inquiry - submitted by the Customer via the form available in the Shop offer inquiries specifying the Product or software being the subject of the inquiry, as well as the Customer data required for contact, indicated in the form.
GDPR - Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation).
Settings (Privacy) - functionality of the Account allowing the User using selected services to properly manage these services, including independent modification of their scope and selection of preferences regarding the protection of their privacy.
User - means an entity for which services may be provided electronically or with which a Contract for provision of electronic services may be concluded in accordance with the Terms and Conditions and the law.
2. Who is the data controller?
The controller of your personal data in connection with the use of online shop services is the company Senetic Limited with its registered office in 7th Floor, Mulliner Towers, 39 Alfred Rewane Road, Ikoyi, Lagos, Nigeria.
Please contact us if you have any questions regarding the processing of your personal data and your rights. Questions regarding privacy protection should be sent to the following email address: firstname.lastname@example.org
3. What personal data do we process, for what purposes and on what legal basis?
Due to the fact that we provide various services for Users of our online shop, we process your personal data for various purposes, in various scope and on a different legal basis set out in GDPR. In order to provide you with the most transparent information, we have grouped the information by referring to the purpose of processing your personal data.
3.1. Creating an Account and authentication of the User in the online shop
The scope of data. For this purpose, we process personal data provided by you in the registration form to the online shop, that is, your name, telephone number, contact details, email address and set password.
Customers can submit a so-called offer inquiry to obtain information on the availability, price and characteristics of a product. To use this feature, you will be asked to provide your name, telephone number, email address and company name. Each time you contact us by phone or email, we will use the information you provide in order to answer your question.
Customers can also place orders for selected products. In case of placing an order for these products, the Customer will be asked to provide data necessary to perform the purchase and sale contract.
Legal basis. Necessity to perform the contract for provision of the Account service (art. 6 (1) (b) of GDPR).
3.2. Services that do not require creating an Account
Types of services. We process your personal data to provide services that do not require creating an Account, such as:
• sending emails with marketing and commercial information,
• display of advertisements.
The scope of data. For this purpose, we process personal data regarding your activity in the Shop, which are: data on viewed products and other pages in the Shop, as well as data on session, your device and operating system, browser, location and unique ID.
Legal basis. Our legitimate interest (art. 6 (1) (b) of GDPR), consisting in facilitating the use of services provided electronically and improving the functionality of these services.
3.3. Services and functionalities requiring creating an Account
Types of services and functionalities. Your personal data is processed to provide services that require creating an Account, such as executing an order.
The scope of data. For this purpose, we process personal data provided in the registration form and data about your activity in the online shop, which are: data on viewed products and other pages in the shop, as well as data on session, your device and operating system, browser, location and unique ID.
Providing some data is a prerequisite for using individual services and functionalities of the Account (mandatory data). Our system automatically marks data. As a consequence of not providing these data we will not be able to provide certain Account services and functionalities. Apart from data marked as mandatory, providing other personal data is voluntary.
Legal basis. Necessity to perform the contract for provision of services in accordance with the Terms and Conditions (art. 6 (1) (b) of GDPR) and our legitimate interest (art. 6 (1) (f) of GDPR) consisting in facilitating the use of services provided electronically and in improving the functionality of these services.
3.4. Statistics of the use of individual functionalities of the Shop, facilitating the use of the Shop′s websites and ensuring the IT security of the Shop
The scope of data. For these purposes, we process personal data related to your activities in the Shop, such as: visited websites and subpages of the Shop and the amount of time spent on each of them, as well as data on search history, your IP address, location, device ID and browser and operating system data.
Legal basis. Our legitimate interest (art. 6 (1) (f) of GDPR), consisting in facilitating the use of services provided electronically and improving the functionality of these services.
3.5. Establishing, pursuing and executing claims
The scope of data. For this purpose, we may process some of your personal data provided in the Account, such as: name, surname, address of residence, data on the use of our services, if the claims result from the manner in which you use our services, other data necessary to prove the existence of a claim, including the extent of the damage suffered.
Legal basis. Our legitimate interest (art. 6 (1) (f) of GDPR), consisting in establishing, pursuing and executing claims and defending against claims in proceedings before courts and other state authorities.
3.6. Handling complaints and requests, answering questions
The scope of data. For this purpose, we may process some of your personal data provided in the Account, as well as data on the use of our services, which are the reason for the complaint or request and data contained in the documents attached to the complaint or request.
Legal basis. Our legitimate interest (art. 6 (1) (f) of GDPR), consisting in improving the functionality of services provided electronically and building positive, based on reliability and loyalty relationships with the customer.
3.7. Customer satisfaction survey
The scope of data. For this purpose, we process your personal data including the data necessary to process the order, as well as your answers to the questions we have prepared, included in the surveys and forms used in the satisfaction survey.
Legal basis. Our legitimate interest (art. 6 (1) (f) of GDPR), consisting in improving the functionality of services provided electronically and assessing the satisfaction with the services we provide.
4. How do we match services to your interests and preferences?
Our online shop aims at the best matching of all marketing messages to your interests and preferences (profiling). In order to provide the most transparent information, below we describe what profiling is about.
4.1. Recommended products
Type of services. Recommended products are presented to you in the Shop before and after logging in, as well as in the form of marketing messages and sent to the provided email address.
The scope of data. For this purpose, we process your personal data provided during the creation of the Account and data related to the execution of orders, as well as data on activity in the Shop, recorded and stored via cookies.
Profiling. On the basis of data obtained this way, we select and present you with the most suitable marketing messages.
Balance of interests. After considering our interest and your interests, rights and freedoms, we believe that presenting recommended products and services combined with profiling will not interfere excessively with your privacy or will not be excessively burdensome. While considering interests, rights and freedoms, we have taken into account the following circumstances:
a. recommended products are a tool providing you with easier access to our offer of products and services, by presenting products you may be interested in. This allows us to assume that processing of personal data for the purpose of recommending products and services is in line with your reasonable expectations;
b. presenting recommended products and services, as well as other marketing communications, and sending them to your email address, is consistent with your reasonable expectations, as you have expressed your desire to receive such communications pursuant to provisions on the provision of services by electronic means;
c. we only use data about your activities in the Shop. We are interested in what products and services you are looking for, which offers have attracted your interest, and not in what you do on other websites;
d. we respect your will and facilitate execution of rights. To this end, we provide the ability to easily withdraw consents to receive recommended offers in the form of notifications in a mobile application, in a web browser and in email messages in the Account settings (Settings (Privacy) tab) or in the browser′s settings.
Legal basis. Our legitimate interest (Article 6 (1) (f) of GDPR), consisting in recommending offers that may suit your preferences and interests.
4.2. Marketing of our products and services and our clients
The scope of data. For this purpose, we process your personal data provided when creating an Account, placing an order and data related to your activity in the Shop, recorded and stored via cookies. Activity data relate in particular to data such as: search history, clicks in the Shop, visits to the main pages of the Shop and their subpages, login and registration dates, data on the use of specific services in the Shop, history and activity related to our email communication.
Profiling. We use the above data to match marketing information about our products and services and our clients that may be of interest to you.
Remarketing. In order to reach you with our marketing messages outside the Shop, we use the services of external suppliers. These services consist in displaying our marketing messages on websites other than the Shop. For this purpose, external service providers install, for example, an appropriate code or pixel to download information about your activity in the Shop. The details are described in the Cookies Policy.
Legal basis. Our legitimate interest (Article 6 (1) (f) of GDPR), consisting in the marketing of our products and services as well as products and services
Balance of interests. Having considered our interest and your interests, rights and freedoms, we have concluded that marketing combined with profiling will not interfere excessively with your privacy or be excessively burdensome. While considering interests, rights and freedoms, we have taken the following into account:
a. you have expressed your desire to receive marketing messages at the provided email address, and therefore we have assumed that you can reasonably expect us to send such messages;
b. we only use data about your activity in the Shop. We are interested in which products and services you are looking for and which offers were interesting, and not in what you do on other websites;
c. we respect your will and facilitate execution of rights. For this purpose, we provide the option to easily withdraw consents to receive emails in the Account settings (Settings (Privacy) tab) or in the browser′s settings.
5. Who do we share your personal data with?
Our databases are protected against access by third parties. Data collected during registration or purchase are used to correctly execute orders, as well as to track the order status and make changes to it at the customer′s request before it is sent. In order to execute the contract, Senetic.ng online shop may share data collected from you with entities such as:
5.1. Service providers
Your personal data are transferred to the service providers we use to run the service. The service providers to whom we transfer your personal data, depending on the contractual arrangements and circumstances, are either subject to our instructions as to the purposes and methods of processing the data (processors) or independently determine the purposes and methods of processing the data (controllers). You will find a list of the providers we use here. The list shall be updated on a regular basis.
Data processors. We use suppliers who process your personal data only on our instruction. They provide us with a cloud hosting service, provide us with online marketing systems, systems to display web push notifications, send email messages, analyze traffic on the website, analyze the effectiveness of marketing campaigns, and support the implementation of specific Account functionalities.
Controllers. We use suppliers who do not act solely on our instructions and set goals and methods of using your personal data themselves. They provide us with services of remarketing campaigns and conduct statistical surveys.
Location. Our suppliers are based mainly in Poland and other countries of the European Economic Area (EEA), e.g. in Ireland. Some of our suppliers are based outside the EEA. Due to the transfer of your data outside the EEA, we have made efforts to ensure that our suppliers guarantee a high level of personal data protection. These guarantees result in particular from the obligation to apply standard contractual clauses adopted by the Commission (EU) or participation in the Privacy Shield program established by Commission Implementing Decision (EU) 2016/1250 of 12 July 2016 on the adequacy of the protection provided by the EU-U.S. Privacy Shield.
5.2. State authorities
Your personal data may be made available to authorized state authorities.
6. How long do we store your personal data?
Your personal data are stored for the period of having an Account in the online shop Senetic.ng for the purposes of providing the Account service and related functionalities and other services in accordance with the Terms and Conditions, as well as for marketing purposes. After deleting your Account, the data will be anonymized, except for the following data: name, email address, order history and information about given consents (we will store these data for a period of 3 years from deletion of the Account for the purposes of handling complaints and claims related to using our services).
Your personal data related to the execution of Orders and License Orders in our Shop are stored for the period required by separate provisions of law, e.g. tax law. At the end of this period, your data will be anonymized.
7. What rights do you have in relation to the processing of personal data?
We ensure execution of your rights indicated below by contacting us via email: email@example.com. Additionally, you can make selected changes to your Account settings in the Settings (Privacy) tab after logging into the Shop.
7.1. Right to withdraw consent.
Pursuant to art 7(3) of GDPR, you have the right to withdraw any consent that has been granted at the moment of registration in the Shop, as well as during the use of particular services and functionalities offered in the Shop. Withdrawal of consent shall take effect from the time of consent withdrawal. Withdrawal of the consent shall not affect processing carried out by us legally prior to such withdrawal.
Withdrawal of consent shall not have any negative consequences for you. However, it may prevent you from continuing to use services or functionality that we may lawfully provide only with your consent.
7.2. Right to object to the use of personal data
Pursuant to art. 21 of GDPR, you have the right to object to the use of personal data, including profiling, if we process them on the basis of our legitimate interest, e.g. in connection with the use of recommended products and services, marketing our products and services, maintaining statistics on the use of particular functionalities of the service and facilitating the use of the Shop, as well as a satisfaction survey.
Resignation from receiving recommended products and services in the form of an email as well as resignation from receiving marketing messages regarding our products or services or our clients will mean your objection to the processing of personal data, including profiling for these purposes.
If your objection is justified and we have no other legal basis for processing your personal data, we will delete the data, processing of which you have objected to.
7.3. Right to erasure
Pursuant to art. 17 of GDPR, you have the right to demand erasure of all or some of your personal data. We will treat any request for erasure of all personal data as a request for deletion of an Account.
You have the right to request erasure of your personal data if:
a. specific consent has been withdrawn in the extent in which the personal data have been processed on the basis of the said consent;
b. the personal data are no longer necessary for the purposes for which they were collected or processed;
c. an objection has been raised to the use of the data in marketing purposes;
d.an objection has been raised to the use of the data for the purpose of maintaining statistics on the use of the service and satisfaction surveys and the objection is deemed justified;
e. personal data are processed unlawfully.
Despite the request to delete personal data, in connection with objection to processing or withdrawal of consent, we may retain certain personal data to the extent necessary to establish, pursue or defend our claims. This applies in particular to personal data including: name, surname, email address and purchase history, which we keep for the purpose of handling complaints and claims related to the execution of orders.
7.4. Right to restriction of processing
Pursuant to art. 18 of GDPR, you have the right to demand restriction of processing of personal data. In the event that such a request is made, you will not be able to use the specific functionalities or services that were related to the processing of data subject to the request until the request is processed. Moreover, we will not send you any messages, including marketing messages.
You have the right to request the restriction of use of your personal data if:
a. the correctness of the personal data has been questioned - the use of the data will be restricted for the time necessary for the verification of their correctness, but no longer than for 7 days;
b. processing of the data is unlawful and the data has been requested to be restricted instead of erased;
c. personal data are no longer necessary for the purpose for which they were collected or used, but are necessary for you to establish, pursue or defend your claims;
d. you have objected to the use of such data, in which case the limitation shall apply for a period necessary to verify whether the protection of your interests, rights and freedoms outweighs the interests we pursue by processing your personal data.
7.5. Right of access by the data subject
Pursuant to art. 15 of GDPR, you have the right to obtain from us confirmation of the processing your personal data is subject to. Where such data are actually processed, you have the right to:
a. obtain access to your personal data;
b. obtain information on the purposes of processing, categories of personal data being processed, the recipients or categories of recipients of the data, the planned period of data storage or criteria for determining this period, rights under the GDPR and the right to lodge a complaint to the supervisory authority, about the source of such data, on automated decision-making, including profiling and safeguards applied in connection with the transfer of these data outside the European Union;
c. obtain a copy of your personal data.
If you wish to exercise your right of access data, please contact the Data Controller, referred to in item 2.
7.6. Right to rectification
Pursuant to art. 16 of GDPR, you have the right to demand that the personal data provided by you are rectified (if they are incorrect) and supplemented (if they are incomplete).
7.7. Right to data portability
Pursuant to art. 20 of GDPR, you have the right to receive personal data that you provided and then to send them to another data controller of your choice. You may also request that we send your personal data directly to another controller, if it is technically possible.
We will send your personal data as a csv file. The csv format is a commonly used, machine-readable format which allows sending the received data to another data controller.
7.8. How long does it take us to meet your request?
If you request to execute the aforementioned rights, we comply with this request or refuse to comply with it immediately, but no later than within 30 days of its receipt. However, if - due to the complex nature of the request or the number of requests - we are not able to meet your request within 30 days, we will meet them within the next 60 days informing you about the intended extension of this period.
For technical reasons, we always need 48 hours to update the settings you choose on our systems. Therefore, it may happen that when you update your systems, you will receive an email from us that you have opted out of.
7.9. Reporting complaints, inquiries and requests
You can report to us your complaints, inquiries and requests regarding the processing of your personal data and exercise of your rights.
If you believe that the right to personal data protection or other rights granted under the GDPR have been violated, you have the right to file a complaint with the General Officer for the Protection of Personal Data.
8. How do we ensure the security of your personal data?
We make every effort to ensure the security of your personal data. The services use encrypted data transmission (SSL) during registration and logging, which ensures protection of data identifying the Users of the online shop and significantly hinders the interception of access to the Client′s Account by unauthorized systems or persons.