SUMMARY OF OUR PRIVACY AND COOKIE POLICY
1. ABOUT US. We are GSR SYSTEM LLC, we process your personal data, acting as a Personal Data Operator. This means that we are responsible for the processing and protection of your data.
2. WHAT DO WE USE YOUR DATA FOR. We use your information (whether collected online or in person) to, among other things, manage your user registration, administer your service purchases, respond to your requests, and, if you choose, send you personalized communications.
3. REASON FOR USING YOUR PERSONAL
DATA. We have legal grounds to process your personal data for several reasons. The main reason is that the processing of your personal data is a necessary condition for the performance of the contract that you enter into with us upon registration, as well as when you make a purchase or use any of our services. We also use your information for other purposes, such as responding to your requests and sending you newsletters that you have signed up for.
4. WHO DO WE GIVE ACCESS TO YOUR
PERSONAL DATA. We only provide access to your data to service providers who assist or support us, and only as required by law.
5. YOUR RIGHTS. You have the right to access, correct or delete your personal data. In some cases, you may also have other rights, such as the right to object to the use or sharing of your data, as detailed below.
We encourage you to read our full Privacy Policy below to fully understand how we will use your personal data and your rights in relation to your personal data.
BEFORE YOU START…
• This Privacy and Cookie Policy will provide you with all the information you need regarding our use of the personal data of our users and customers, regardless of the channel or medium (online or in person) you use to interact with us.
• We apply the principle of transparency in relation to all transactions carried out with your personal data, so that you fully understand how and why we use your data, and what rights you have in relation to your data:
o We provide you with permanent access to our Privacy and Cookies Policy and all information provided therein. You can view it at any time.
o You can also obtain more detailed information about how we use your data by further interacting with us.
• Below are a number of terms that are mentioned regularly in this Privacy and Cookie Policy.
o The term “Platform” generally refers to any channels or means you use to interact with us (whether digitally or in person). The main one is the following:
▪ Our Website.
1. WHO IS YOUR DATA CONTROLLER?
Data operator:
▪ GSR SYSTEM LLC company
o Postal address: 364024, Chechen Republic, Grozny, st. them. N. A. Nazarbayeva, 92, 8th floor, office 8-20
2. WHY DO WE PROCESS YOUR PERSONAL DATA
Depending on the purposes for which we process any of your personal data from time to time, as set out below, we need to process the following types of data on a case-by-case basis:
▪ information proving your identity (for example, your first name, last name, photograph, language, country in which you are located, contact details, etc.);
▪ economic information and transaction data (for example, payment and bank card information, information about purchases, orders, returns, etc.);
▪ connection data, geographic location and/or browser data (for example, location data, device identification number, advertiser ID, etc.); ▪ commercial information (if you have subscribed to our newsletter, etc.);
▪ information about your tastes and preferences.
Please remember that whenever you are required to provide your personal information to gain access to any feature or service of the Platform, certain fields will be marked as required to fill out: We need this information to provide you with the service you require or to provide you with access to certain options and features. Please note that if you choose not to provide us with this information, you may not be able to register or use the services or options listed.
In certain cases, a third party may have provided us with information about you by using a feature or service on the Platform, such as sending you a gift card or shipping an order to your address. In these cases, we process your data only to the extent that it is relevant to such feature or service, as described in this Privacy Policy and Cookie Policy.
In other cases, we may collect information passively through the use of tracking tools such as browser cookies and other similar technologies on our Platform and in the materials we send to you.
Depending on how you interact with the Platform, that is, what services, products or options you are interested in, we process your personal data for the following purposes:
1. Managing your registration as a user of the Platform
If you decide to become a registered user of our Platform, we need to process your data in order to identify you as a user of the Platform and provide you with access to its features, products and services (as a registered user). You may delete your registered user account by contacting our customer service department.
We hereby inform you that the data about your activities that we collect through other channels of the Platform, which includes information about your purchases, will be associated with your account so that aggregate information can be accessed.
2. For the purpose of concluding and executing a contract for the sale of goods or provision of services that you enter into with
by us on the Platform
This includes the processing of your personal data primarily for the following purposes:
▪ To send you updates and notices regarding features, products and services that are the subject of the contract, including quality surveys to determine customer satisfaction with the services provided.
▪ To administer payment for goods and services you purchase, regardless of the payment method you choose. Example:
▪ If, when purchasing any of our products on the website or through the application, you choose to enable the option to save your payment details for future purchases (if available), we need to process this data in order to enable this feature. If you agree to activate this option (autofill option), your payment information will automatically appear in the appropriate fields for future purchases. This way, you will not need to re-enter them for each new transaction, and the data provided will be considered valid for future purchases. You can change or delete your payment information at any time by going to the payment information section of your registered user account on the website or the «My Account» section of the application.
▪ To activate the mechanisms necessary to prevent and detect unauthorized use of the Platform, for example during the purchase and return of goods, as well as possible fraudulent activities committed against you and/or against us. If we believe that a transaction may be fraudulent, or detect unusual behavior that indicates an attempt to fraudulently use our features, products or services, such processing may result in blocking the transaction or terminating your user account.
▪ To process possible exchanges or returns of goods after their purchase, as well as manage requests for the availability of goods and bookings of goods through the Platform, depending on the availability of these options at one time or another.
▪ For the purpose of billing and providing receipts and invoices for purchases made through the Platform;
3. To provide responses to inquiries and requests made through customer service channels
We only process personal data that is strictly necessary to process your applications or answer the questions raised in them.
If you contact us by telephone, the call may be recorded to monitor quality of service and to enable us to respond to your request.
If you choose to use chat on social networks and other resellers (if available) as your customer service channel, some of your personal data, such as your name or username, will be imported from the social network or reseller account. Also, remember that the data you submit to this service will be available to your social network or intermediary and is subject to their privacy policies, so we recommend that you check your privacy settings and read the social network or intermediary’s privacy policies for more detailed information about how they use the personal data of users of their services.
4. For marketing purposes
This involves processing your personal data for the following purposes:
▪ To personalize the services we offer you and to enable us to provide you
recommendations based on your interactions with us on the Platform and analysis of your user profile (for example, based on your purchase and browsing history).
If you subscribe to our newsletter, we process your personal data to administer your subscription, including sending personalized information about our products and services through various means of communication (such as email, instant messengers and SMS messages). We may also provide this information to you via push notifications if they are enabled on your device;
▪ Please note that the processing of your personal data includes the analysis of your user or customer profile in order to identify your preferences and take into account, when sending you information, which products and services best suit your personal style. For example, based on your purchase and browsing history, we will send you product recommendations that we think may be of interest to you. If you are a registered user, you will have access to a reminder function for an order that you have not completed;
▪ Remember that you can unsubscribe at any time at no additional cost. This can be done in the «Newsletter» section of the Platform and by following the instructions in each notification. If you do not want to receive notifications, you can disable the corresponding option on your device;
▪To show you online advertisements that you may see when you visit websites and applications, such as social networks. The advertisements you see may be random, but in some cases they may be related to your preferences or purchase and browsing history.
▪ If you use social media, we may share certain information with companies we partner with so that they, as Joint Owners, can display advertisements for our brand to you and, generally, provide you and users like you with advertising.
ads that take into account your profile on specified social networking sites. If you would like to learn more about how your data is used and how social media advertising works, we recommend that you review the privacy policies of the social media sites on which you have profiles.
▪ We also use your data to perform calculations and segment analysis on the advertisements we display to users on some of our partners’ platforms. For this purpose, we partner with such third parties who offer us the necessary technology (e.g. cookies, pixels, software development kits) to use these services. Please note that we do provide them with some identifying information each time (for example, an advertising identifier associated with a device, an identifier associated with a cookie, etc.). If you would like to know more about this, please see our Cookie Policy. You can also reset your advertising ID or stop receiving personalized ads on your device by changing your device settings.
▪Data Enrichment: When we collect your personal data from various sources, in certain circumstances we may combine it to better understand your needs and preferences related to our products and services (including for the purposes of analysis, generating user profiles, market research, quality control and improving our interactions with customers). This applies, for example, to: combining your data if you have a registered account but make a purchase without registering using the same email address associated with that account; automatic compilation of information (such as IP and MAC addresses or metadata) that we may link to data provided by you directly through your activities on the Platform or in any of our stores (for example, this may be information related to your purchases in physical stores or online, your preferences, etc.).
▪ To conduct promotions (for example, to organize contests, sweepstakes, or send a list of available products to the email address you provide). By participating in any promotion, you consent to the processing of any personal data you provide based on the nature of the promotion through means such as social media or the Platform. If you participate in any promotion, you will be provided with terms and conditions of participation containing more detailed information about the processing of your personal data;
▪ To distribute to users of the Platform or through our social media channels photographs that you have published publicly and for which you have provided your express consent to be used for the relevant purpose.
5. Analyzing user experience and quality to improve our services When you access our Platform, we inform you that we will process data about your navigation for analytical and statistical purposes, in particular to understand how users interact with our Platform, as well as with the promotions we run on other websites and applications, in order to improve our services.
In addition, we periodically conduct quality surveys and take the necessary measures to determine the level of satisfaction of our customers and users and identify areas and areas for improvement.
3. WHAT LEGAL BASES GIVE US THE RIGHT TO PROCESS YOUR PERSONAL DATA
The legal basis that gives us the right to process your personal data is based on, among other things, the purposes for which we process it, as set out in the table below:
1. Managing your registration as a user of the Platform
We process your data because it is necessary in accordance with the terms and conditions governing the use of the Platform. In other words, in order for you to register on the Platform as a user, we need to process your personal data. Otherwise, we will not be able to manage your registration.
We have a legitimate interest in linking purchase information and activity data collected across various channels of the Platform to your account.
2. To conclude and execute a contract for the sale of goods or provision of services
We process your data because it is necessary to enter into a contract with you for the sale of goods or the provision of services.
Certain data processing related to the purchase process is enabled only because you request or authorize it, such as storing payment information for future purchases or enabling “Coming Soon” or “Back on Sale” alert options (where available). In these cases, the processing of your data is carried out on the basis of your consent. We also process your location data when you give us consent to offer you specific services through the app when you visit some of our stores.
We believe that we have the legal right to implement appropriate verification procedures when making a purchase or return in order to identify and prevent potential abuse or fraud in the use of the Platform. We understand that the processing of such data is in the interests of all parties involved: for you, as it allows us to take steps to protect you from fraud attempts made by third parties, and for us, as it allows us to prevent unauthorized use of the Platform; for all our customers and society as a whole, as it protects their interests by preventing fraudulent activity and detecting it when it does occur.
3. User service
We believe that we have the legal right to respond to any of your requests through the various communication channels available. We understand that the processing of such data is also in your interests to the extent that it allows us to provide you with appropriate support and answer your questions.
In particular, the processing of your data is necessary for the execution of a sales contract or the provision of services when contacting us to resolve unforeseen situations related to your order or product/service purchased through the Platform. If your request relates to the exercise of your rights, which we inform you about below, or a claim in relation to our products or services, then we have a legal right to process your data in order to comply with our legal obligations.
4. Marketing
We have the legal right to process your data for marketing purposes based on the consent you give us, for example by agreeing to receive personalized information through various channels, agreeing to receive push notifications on your mobile device, setting appropriate privacy settings on your mobile device, agreeing to cookie settings, or agreeing to the legal terms and conditions to participate in a promotion or to publish your images on the Platform or our social media channels.
We believe that we have a legal right to carry out profiling based on the information we have about you (including your browsing history, preferences or purchases) and based on the personal data you have provided to us, including age group or language, in order to provide you with personalized services or display personalized information on our Platform or on third party platforms, and for data enrichment purposes, as we understand that such data is also processed in your interests, as it allows you to improve your experience as a user and access information according to your preferences.
5. Analysis of user experience and quality
Based on our legitimate interest, we analyze user experience and user satisfaction with the Platform. The processing of this data is also carried out in your interests, since its purpose is to improve your user experience and provide you with better services.
4. HOW LONG DO WE KEEP YOUR PERSONAL DATA?
The retention period for your personal data depends on the purposes for which it is processed, as follows:
Personal data storage period
1. Managing your registration as a user of the Platform
Your data will be processed for as long as you remain a registered user (that is, until you decide to unsubscribe).
2. Drawing up and execution of a contract for the sale of goods or provision of services
We process your data for the period necessary to conclude and perform a contract for the sale of goods or services, including potential returns of goods, as well as complaints or claims related to the purchase of said goods or services.
In some cases, we process data only until you decide otherwise, such as in the case of payment information that you have requested to be saved for future purchases (if applicable).
3. Customer Service
We process your personal data for the period necessary to respond to your request.
4. Marketing
We process your personal data until you unsubscribe from the newsletter.
Similarly, we will show you advertisements tailored to your individual interests unless you change your device, browser or cookie settings to revoke permission.
If you participate in a promotion, we will retain your data for six (6) months from the end of the promotion.
5. Analysis of user experience and quality
We process your data as necessary for as long as necessary for us to complete a procedure or study for quality assurance purposes, or until we anonymize your browsing data.
Although we process your data strictly for the period necessary to achieve the required purpose, we subsequently ensure that it is properly stored and protected for the period during which liability may arise in connection with its processing in accordance with applicable law. We delete your personal data after the statute of limitations for potential liability has expired.
5. DO WE SHARE YOUR DATA WITH THIRD PARTIES
To achieve the purposes set out in this Privacy and Cookie Policy, we must also provide access to your personal data to third parties who support us in providing services to you, including:
▪ financial institutions;
▪ institutions and services involved in identifying and preventing fraud;
▪ providers of technological and analytical services;
▪ service providers and partners related to logistics, transport and delivery, and (or) their partner organizations;
▪ companies providing services related to customer service;
▪ service providers and partners related to marketing and advertising, such as social networking websites, advertising agencies and advertising partners.
6. WHAT RIGHTS DO YOU HAVE WHEN PROVIDING YOUR DATA TO US?
We are committed to ensuring the confidentiality of your personal data, as well as the necessary conditions for the exercise of your rights. You can exercise your rights free of charge by sending a letter to the legal address indicated above indicating the reason for your request and the right you want to exercise. If necessary, we may ask you to provide us with a copy of your identification document.
In addition, we may offer you the opportunity to exercise your rights and set your privacy preferences when using some of our services or by providing certain channels within our Platform.
In particular, regardless of the purpose and legal basis for processing your data, you have the following rights:
• Request access to personal data held by us. We remind you that if you are a registered user of the Platform, you can view this information in the appropriate section of your account.
• Request corrections and changes to the personal data in our custody. Please note that if you are a registered user of the Platform, you can change or update your personal data in the appropriate section of your account on the Platform. Please note that by providing us with access to your personal information through any means, you agree to ensure its accuracy and reliability, and to notify us of changes to it. You are responsible for any damage caused to the Platform or the person in charge of the Platform or any third party if you provide us with erroneous, inaccurate or incomplete registration information. Please note that you are generally only required to provide us with your personal information and not that of third parties, unless otherwise stated in the Privacy and Cookies Policy.
• Request erasure of your personal data where it is no longer necessary for the purposes for which we needed to process it as set out above, or where we no longer have a legal basis for processing it.
• Request deletion or restriction of processing of your personal data. This means that in certain cases you can request that the processing of your data be suspended or stored for a longer period than necessary.
If you have given us your permission to process your data for any purpose, you also have the right to revoke that permission at any time. Some of the circumstances in which you may withdraw your consent are set out in Section 2, which sets out the purposes for which we process your personal data.
If you do not want us to share information with third parties to serve you advertisements, you can opt out in a number of ways, including by changing the settings on your device, changing your browser and/or cookie settings, and by reviewing the privacy policies and settings on social media sites where you have profiles, or by sending us an email at the email address above with information about your request.
Where we have a legal right to process your personal data based on your consent or for contractual purposes, as set out in section 3, you also have the right to request transfer of your personal data. This means that you will have the right to receive the personal data you provide to us in a structured, universal and machine-readable format, and to transmit it directly to other institutions, without any hindrance on our part.
In addition, where the processing of your data is based on our legitimate interests, you also have the right to object to the processing of your personal data.
7. WHAT HAPPENS WHEN YOU PROVIDE US WITH THIRD PARTY DATA OR WHEN A THIRD PARTY HAS PROVIDED US WITH YOUR DATA?
We offer features or services that require us to process third-party personal data that you, as a user or customer, must provide to us, such as when you authorize a third party to pick up an order from our stores or partner organizations. If you provide us with personal data from third parties, or if we need to request data from a third party when receiving an order for you, you confirm that you have notified such third party of the purposes for which we require and how we will process their personal data.
If any third party has provided us with your information, or if you have provided it yourself, by using a feature or service requested by one of our users, we will use it to manage that feature or service on a case-by-case basis to the extent specified in this Privacy Policy and Cookie Policy, a reference to which is always included in our communications.
8. CHANGES TO PRIVACY AND COOKIE POLICY
We may, at our discretion, make changes to the contents of this Privacy and Cookies Policy. In this case, we will notify you of these changes using certain functions of the Platform (for example, a banner, pop-up notification or push notification). In addition, we may send notice to your email address in cases where changes are made in any way related to the protection of your privacy, so that you have the opportunity to review such changes and, if you wish, to refuse or unsubscribe from any service or option. We encourage you to periodically review the Privacy and Cookie Policy for possible changes and online for changes and improvements. This document is always freely available on our Website and in our App.
9. INFORMATION ABOUT COOKIES
We use cookies and other similar tools to enhance your experience on our Platform, to obtain information about how you interact with the Platform, and, in certain cases, to be able to show you advertisements based on your previous browsing. Please review our Cookies Information to better understand them and the other tools we use, what they do, how to manage your preferences, and other information that may be of interest to you.
Cookie Policy
BEFORE YOU START…
This cookie policy provides information about the use of cookies and similar devices installed on the terminals of our customers and users. In some cases, cookies may be related to the processing of personal data, so we recommend that you read the Privacy Policy document available on our Platform if you want to know how we process the personal data of our customers and users, how to exercise your rights, or what terminology we use in relation to our Platform (website, application or physical stores).
INFORMATION ABOUT COOKIES
What is a cookie?
A cookie is a small text file, like a label, to identify your device. It is installed by a website, app or other platform on your computer, tablet, smartphone or any other similar device and contains information about your navigation or activities. Cookies are necessary, for example, to provide a better navigation experience and to track how users interact with the platforms in order to make improvements. They also serve to tailor the display of advertisements to user preferences and for other purposes described below. Cookies do not cause any harm to your computer or other device.
By «cookies» we also mean other similar technologies that install and/or collect information about your device (such as flash cookies, web beacons or bugs, pixels, HTML5 (for local storage) and application SDK technologies. The term «cookies» also refers to the use of fingerprinting technology, that is, methods of combining data to identify your device. In some cases, these technologies are used in conjunction with cookies to collect and store information to enable certain features and services to operate on your device. our Platform or to show you advertisements on third party platforms based on your navigation.
This general information about what cookies are is provided for informational purposes only. More detailed information about which cookies we use can be found in the cookie settings panel on our Platform.
What types of cookies are there?
Please read this section to get a general understanding of the typology of cookies used online.
Depending on the owner, cookies can be classified as follows:
a. Own cookies. These are those files that are sent to the user’s computer or device from a computer or domain controlled by the publisher itself, and from which the platform or service requested by the user operates.
b. Third party cookies. These cookies are sent to the user’s computer or device from a computer or domain that is not managed by the publisher itself, but by another organization that processes the data obtained through cookies.
Depending on their purpose, cookies can be classified as follows:
a. Necessary (technical) cookies. These files enable the user to navigate within a website, platform or application, as well as use the various options or services available therein. Such as monitoring traffic, identifying data or a session, browsing restricted sections or content, remembering items in an order, making a purchase, making a payment, monitoring service security and potential fraud, using security features during navigation, requesting registration or participation in a promotion, storing data for publishing videos or audio files, activating dynamic content (for example, animations when loading text or images), or publishing content on social networks. Technical cookies are mandatory and are therefore downloaded by default to guarantee access to the platform or provision of a service to the user.
b. Functional or personalization cookies. These cookies allow information to be remembered so that the user can access a platform or service with certain characteristics that distinguish his session from those of other users. This could be, for example, the language, the number of search results on the page, the appearance or content of the service depending on the type of browser used or the region from which the service is accessed, and so on. Failure to use these cookies may result in a slower website performance or inappropriate recommendations.
c. Analytical cookies. These files allow you to monitor the number of users, traffic to sections of the platform and interactions with it, as well as measure and perform statistical analysis of user behavior in order to implement improvements based on the analysis of data on user interaction with the platform or service.
d. Advertising cookies based on user behavior. These files store information about user behavior by constantly tracking their repeated browsing actions in order to create a specific profile for displaying advertisements. These cookies enable you to get the most out of advertising spaces that the publisher uses directly or in collaboration with a third party.
What are cookies used on our Platform for?
Cookies form an integral part of our Platform. Their main goal is to make user navigation as convenient and efficient as possible. For example, they are used to remember your preferences (language, country, etc.) during navigation and for subsequent visits. In addition, we use cookies to continuously improve our services and the Platform, and to show personalized advertisements based on your browsing habits.
We use information obtained through cookies to improve our Platform based on statistics and usage patterns (number of visits, most visited sections, session times, etc.). In addition, these files allow us to collect statistical data about user interaction with the Platform in order to improve services and tailor the Platform to your interests, for example, for faster searches, etc.
In some cases, through the use of cookies, we may receive information to display advertisements based on an analysis of your browsing behavior (viewing products, visiting sections, etc.) on our Platform, on third party platforms or in any other digital spaces.
In any case, our cookies never store personal information such as passwords, credit or debit card details, etc.
How can you control the use of cookies on this Platform?
In the cookie configuration panel, which is always available on our Platform, you can obtain all the information about the cookies used on this Platform, as well as learn about the purpose, duration and management (your own or third parties) of each of them, in order to control the inclusion and disabling of those cookies that are not strictly necessary for the functioning of the Platform.
You can also disable cookies in your browser when you browse the Internet. The following is information on how to do this in some of the most common browsers:
• Safari
This option to refuse cookies can be used at any time.
Please note that both the options in the cookie configuration panel and the ability to refuse cookies depend on your browser. Therefore, if you have configured cookies on one device and want to apply the same settings to another device, you will need to enable the same option on that device.
In addition, with respect to third party cookies required to serve ads tailored to your interests, please be aware that individual third parties may participate in one of the following programs to automatically adjust ads based on online behavior, with appropriate opt-out options:
• Network Advertising Initiative (NAI) — http://www.networkadvertising.org/choices/ • Google Analytics — https://tools.google.com/dlpage/gaoptout
Who uses the information stored by cookies?
The information stored by cookies on our Platform is used only by us, except in the cases specified in section 2 as “Third Party Cookies”, where cookies are used and managed by third parties who provide digital services to us in order to improve our services and user navigation on our Platform. More detailed information can be found in the cookie configuration panel, which is always available on our Platform.
For more information about the processing of personal data as part of our cooperation with third parties and international data transfers, you can consult the Privacy Policy document available on our Platform and the privacy policies or privacy settings on third party platforms.