PRIVACY AND DATA PROTECTION POLICY
LC WAIKIKI RETAIL RS d.o.o. Beograd-Stari Grad, a company registered and functioning under the Serbian laws, with headquarters in Serbia, Belgrade, Kneza Mihaila Street, no. 44 Belgrade, duly registered with the Serbian Business Registry Agency under registration no. 21097551, TIN no. 108942206, email: firstname.lastname@example.org
, contact phone number: 011/4427-469, part of the international LC WAIKIKI group of companies under the organization of LC Waikiki Mağazacılık Hizmetleri Tic. A.Ş. (the “Company”
) respects the privacy of its customers and uses its best effort to ensure the protection of their personal data and information, by complying with all applicable legislation relating to the protection of personal data.
For this purpose, we implement the following Privacy and Data Protection Policy (“Policy”), which sets out the main aspects in relation to which personal data we collect and process on our Website, for what purposes we collect and process such data, how we use such information, how you can change such information, your preferences for our communication with you as well as how we ensure the protection of such personal data and your rights relating to your personal data.
We comply with the applicable legal provisions and the personal data we receive and/or collect from you, process, store or keep, are processed according to the applicable legislation and exclusively for the purposes provided within this Policy.
It is important to mention that this Policy applies to you irrespective of the manner how you access our website, respectively it covers any device through which our Website is made accessed by you (via phone, tablet, PC etc.).
Mention should be made that our cookies policy is part of this Policy.
This Policy re your data related to online sale is related to customers who are physically located in Republic of Serbia.
- Acceptance of the Privacy and Data Protection Policy
Before further action on our Website, we strongly recommend you to read this Policy carefully.
If you do not agree with this Policy and you do not want your personal data to be used as it is detailed herein, you should not continue to use our Website and not provide us with your personal data.
We underline that every time you use our Website, you are subject to our Policy and by further accessing, browsing and otherwise using our Website, you confirm that you have read, understood and consented to this Policy.
- What Personal Data We Collect
- Personal data
When you access or browse our Website, as well as when you make online purchases through our Website, when you subscribe to our e-bulletins and website which announce our services and campaigns, we will collect some of your personal data, including some of sensitive data as defined under the applicable legislation, to serve you better, such as:
- your name, family name, gender, date of birth;
- address, e-mail address, phone number;
- billing details and delivery addresses;
- feedback, browsing;
Please note that
- personal interests, shopping preferences, shopping history, views of products, clicks, add to cart;
- order number
- IP address
- your location, i.e. city of residence.
; in order for you to be able to create a personal account on our Website and to make any online purchase, it is mandatory for you to provide us with all the personal data such as name and family name, date of birth, address, email address, phone number, billing details and delivery address. If you do not agree to provide to us such personal data, you will not be able to create your own personal account and/or to make purchases on our Website.
Namely, Company collects and process your personal data for the purpose of conducting of online sale and entering into agreement on online sale i.e. processing i necessary for the purpose of performance of the agreement entered into data subject or for performance of the actions, at the request of data subject, before entering into agreement. By filing specific form for services which are offered on our Website, i.e. by creating your private account on our Website, You confirm that You are informed on this Policy and that You accept it.
Further, personal data for the purpose of marketing and sending of e-bulletins, sending of surveys on customer’s satisfaction, evaluation of the satisfaction of the customer with service of purchase, are processed solely based on your consent. You give the consent to Company for collecting and processing of your personal data and you can recall the consent given at any time by sending the statement to the Company at email or mail address as determined further below. Upon receipt of recall of consent the Company is committed to destroy all data and not to save it or use it any further. The recall of consent does not affect the legality of the processing which was performed based on consent before such recall.
- Technical and statistical data and information
We mention that, beside the personal data detailed above, we can collect information about your device, as well as other statistical and technical data and information, such as frequency and duration of your visit of the Website, times of ordering and IP address at the time of ordering, statistics about product pages visited and ordered products.
These data are collected and used by us in order to analyze your visitor actions and preferences based on consent, and to administer the website, for statistical purposes and for security reasons based on our legitimate interest.
The statistical and technical data provided by your browser and/or device can also be used for marketing and advertising purposes, with the mention that these data will not be connected with your personal data and will not be used to identify you.
- Data and information regarding the payment (bank information and/or payment card details)
As part of the processing of any order, and depending on the payment method selected by you when placing your order, you will be requested to provide data regarding your bank account, information regarding your credit card, and such data shall be used both for performing any payments to us or for our refunds to you, as the case may be.
We recommend you to read these terms and conditions before selecting this payment method. The credit card information used for placing your order shall never be kept or stored in our system.
- How We Use Collected Personal Data
Accordingly, we collect your personal data for the following purposes:
- To create a private account for you on LC WAIKIKI RETAIL RS website (e.g. your name, email);
- To process your orders through online services (e.g. your name, address, date of birth);
- To send SMS notifications to inform you about deliveries (e.g. your cell phone number);
all for the purpose of performing the actions at your request prior conclusion of the agreement and execution of the agreement,
- To send marketing offers such as news bulletin and catalogues (e.g. your e-mail address, name and mail address) based on Your consent;
- To inform you about delivery problems relating to your ordered products (e.g. your phone number, street address) for the purpose of execution of obligation under agreement;
- To respond to your queries and inform you about new or changed services (e.g. your e-mail address);
- To analyze your personal information so that we can provide you with marketing offers and information that fits your preferences, to provide personalized reccomendations, to enhance the customer experience and to create the campagne for customers (e.g. your e-mail address, shopping habits, click, add to cart products, viewed products, other technical and statistical data) based on consent;
- To verify that you are of legal age for online shopping (e.g. your date of birth) for the purpose of execution of the agreement.
- To send the surveys on customers satisfaction in order that you may provide to us the ratings, comments and recommendations re providing of service of purchase through our website based on your consent,
- to process and analyse your rating, comments and recommendations provided by you in the survey, based on your consent, so we may enhance online purchase from our website.
- to process and analyse your rating and comments given by you in the survey regarding satisfaction of the provided service by our Call Center, for the purpose of measure of satisfaction and improvement of the work of our Call Center.
Please note that; we do not and will not knowingly collect information from any unsupervised person under the age of 18. If you are under the age of 18, you must not use this Website or submit any personal data to us.
Moreover, the personal data collected by the us through Website shall be used also for the following purposes:
- To process and complete ordering processes and to ensure communication with our customers, in order for us to fulfil our obligations deriving from any transaction concluded between our customers and us;
- To provide you with information about our products, services, campaigns, promotions and other notices and/or information, based on Your consent;
- To gain a better understanding of our customers' shopping preferences and to further offer them a personalised experience on our website, and improve the use of same and service, based on consent;
- To carry out trend and statistical analyses, including for marketing and other intern purposes of the company for acquiring of our legitimate interest;
- To reinforce website security for acquiring of our legitimate interest.
- To obtain the feedback from our customers on their satisfaction with the purchase through our website, and to improve our services, based on consent.
When customer calls our Call Center for any reason after shopping online or in the store, a customer Call ID related to such call will be given. We will send sms to customer with survey link containing questions re satisfaction of the provided service by Call Center. The processing of your data (your phone number, email address, customer Call ID and your suggestion and opinion) is carried out based on your consent and only for purpose of analysis and improvement of the work of our Call Center.
Company stores in a systematic manner the collected data for the purpose of entering and execution of sale contract only during commercial relations between Company and You, as determined under related agreement, provisions and conditions of Company and other related general acts of the Company, i.e. within the term set out by law on accounting and related regulations. Once your personal account on the website of Company LC WAIKIKI RETAIL RS doo is cancelled or deleted, without obligations or debt towards Company, the Company shall immediatelly delete all personal data that you gave and which were collected in accordance with this Privacy and Data protection Policy, except the data which Company is obliged to keep in accordance with and within term prescribed under accounting regulation and regulation of protection of rights of consumers.
LC Waikiki Retail RS inform you that in case of deletion or cancellation of your private account on the website, specific personal data such as: data on pages of products which you visited and ordered products, browsing, statistical data will be anonymized and further processed only for statistical purposes and shall not be in any way related to you, based on legitimate interest of LC Waikiki Retail RS. LC Waikiki Retail RS provides the implementation of the technical, organizational and personnel measures, i.e. anonymization of data in a manner that it is unabled identification of person, and with respect of the principle of minimization of data.
Data collected based on our legitimate interest, shall be kept until such legitimate interest exists, in accordance with law.
Data collected for the purpose of marketing based on Your consent, shall be kept until withdrawal of consent which may be given in any time.
Data collected for the purpose of evaluation of satisaftion of customers, by surveys on satisfaction with our services, based on Your consent, shall be kept 2 years, and in any case until withdrawal of consent which may be given in any time.
Data collected for the purpose of analyse of shopping habits of customers, improvement of customer’s experience, providing of personalized recommendations, based on Your consent, shall be kept 5 years, and in any case until withdrawal of consent which may be given in any time. After withdrawal of consent the data processing is not allowed, but withdrawal does not affect the legality of processing based on withdrawal before such withdrawal. Mentioned data (your email address, purchase history, shopping habits, clicks, views, add to cart) are disclosed and shared only to company - service provider of services of analyses from Turkey, and transfer to Turkey as country which provides the adequate level of personal data protection.
Data collected for the purposes of measuring and analyses of your satisfaction of Call Center's service and improvement of work of our Call Center are kept for 1 year, and in any case until withdrawal of consent which may be given in any time. Data (phone number and Customer Call ID) are disclosed and shared to service provider from Turkey, and transfer to Turkey as country which provides the adequate level of personal data protection, and data (Customer Call ID and your suggestion and opinion from survey) are processed and shared to service provider which servers are located in USA, upon your consent with prior notification about the potential risks re such transfer, and which consent may be withdrawn in any time.
For what purpose and based on which legal ground do we use your personal data?
- We use behavior analytics tool that helps us understand how users interact with our website. Supported features captures the user interactions on our website such as, how the page is rendering, user interactions such as mouse movements, clicks, scrolls, and so on. So we will be to make data-driven decisions on what works and what doesn't, understand confusing elements of our webpage, identify user behavior and add required content to our page, test and publish new ideas on our webpage, study user clicks and scrolling behavior and provide better customer experience on our websites.
- Data gathered by Advertising Cookies, advertising technologies and other online identifiers, search history, accessed content on our Website.
- To target our advertising banners, more precisely to show you LC Waikiki advertising on Social Media platforms or on other websites you use.
We use for such purpose several digital marketing networks, ad exchanges and advertising technologies such as advertising cookies, web beacons, pixels, online identifiers, ad tags, including specific services offered by sites and Social Media, such as, Facebook’s Custom Audience service.
- How We Share Collected Personal Data
The personal data collected on the website may be shared with, disclosed to or processed by our personnel or partner companies that provide related services (such as companies providing cargo and delivery services, call centres, database services, advertising and marketing agencies, services of analyse of shopping habits of customers, services of measuring of satiscation of the services of our Call Center, etc.).
We can disclose and/or transfer your personal data to our mother company LC WAIKIKI Mağazacılık Hizmetleri A.Ş in Turkey, and the group companies of LC WAIKIKI Mağazacılık Hizmetleri A.Ş., but also to relevant governmental authorities where law so requires, in order to better serve our customers and fulfil our obligations towards customers.
However, your personal data is in any case protected by the Company and we also make sure that such companies with which your personal data is shared to protect and ensure privacy of the same level for your personal data.
Personal data and other information we collect from you can be transferred outside Serbia to any country which is member of European Union. By agreeing to the terms and conditions of this Policy you give your consent for delivery and transfer of data to the relevant related companies of LC Waikiki in the listed countries only, which provide the adequate level of personal data protection.
In case of transfer of data to countries or parts of countries in which there are determination that provide adequate level of protection of personal data, Company states and warrants that collected data will be transferred strictly in accordance with the Law on Personal Data Protection of Republic of Serbia, i.e. that appropriate measures for protection of these data are provided and that to data subject are provided the exercising of its rights and efficient legal protection. For more information on transfers of personal data outside Republic of Serbia, you can contact LC WAIKIKI.
Other than that, your personal data is never disclosed to any third parties, whether real persons or legal entities that have no commercial relationship with us for the purposes of this Website, and is not used or sold for any commercial purpose.
In the event another company is interest to acquire all or a part of our business, we reserve the right to disclose your personal data and other information to that company, solely in connection with and for the purposes of the envisaged acquisition.
As far as the exclusion is and up to the limits permitted under the applicable legislative, we have no control and assume no liability for the transfers of your personal data and other information performed by other partner companies that provide related services on our website or in connection hereto.
By ordering and purchasing of our product through our website, you gave consent that we may send surveys of satisfaction of our services to Your email address.
Such surveys include questions re your ratings, comments and recommendations re our services. Please note that such provided data (including gender, age, city of residence) will be processed anonymously by our internal team and will be shared anonymously (not related to you) through servers to our parent company in Turkey. Except for the data shared by the customers via surveys (ratings of service, gender, age, city of residence, order number, IP address), personal data such as your name and surname and e-mail will not be shared.
By contacting our Call Center, you give consent to send you survey re service satisfaction from Call Center.
Before you completing the survey and sending the survey to us, You give the consent for processing and transfer of personal data, for purposes and in manner as explained in this Policy.
- Cookies policy
This section refers to the cookies and web pages operated by LC WAIKIKI RETAIL RS doo. Please note that in order to insure the proper functioning of this Website, we sometimes place small data files called cookies on your device.
A cookie is a small text file (letters and numbers) that a website places on your computer, telephone or any other device when you visit the website, with information about your navigation on that website. The cookies are installed by request issued by the web-server to a browser (e.g.: Internet Explorer, Chrome) and does not contain any software, spyware or virus programs and cannot access information from the hardware of the user. The function of the cookie is to enable our website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.
The cookies are industry standards used to make sure that your shopping on our Website is more efficient and safe and cookies are used on all shopping websites.
Moreover, the information collected in the cookies allows us to improve the Website and to adapt its content to the user’s preferences and individual needs, to improve the result of the searches, to maintain and enhance the functionality and performance of the Website, by which we acquire our legitimate interest.
The cookies used on the Website are, in all cases, of a temporary nature, used solely to improve the efficiency of the last transmission. The cookies used by the website are solely associated to anonymous users and their computers and do not provide personal details on users.
If you do not accept application of these cookies, the same will not be in function and will not be set on your browser and we will not process personal data for the mentioned purposes.
The cookies used by our Website will not be used for any other purposes than the ones stated.
What type of cookies are used on this website?
Our Website uses the following types of cookies:
These allow the user to browse our Website and use functions such as the shopping basket or wish list for the purpose of execution of shopping and entering into agreement.
Company LC WAIKIKI RETAIL RS doo uses analytics cookies to calculate the number of users who visit its website and are registered. These cookies make it possible to measure and analyze the way in which users browse this Website.
Whenever users are browsing or shopping on this Website, the site will remember their preferences (e.g. their location or preferred language). Thanks to these cookies, we are able to offer users a simple, more convenient and personalized browsing experience.
These cookies are used to show advertisements that are relevant to users and helps LC WAIKIKI RETAIL RS to measure the effectiveness of its advertising campaigns. When browsing on the Website, users give consent and accept that LC WAIKIKI RETAIL RS will download these types of cookies on their devices and will consult when the user visits the Website in the future.
- Cookies for analysis of your shopping habits, clicks, add to cart for the purpose of improvement of user experience and providing of personalized recommendations, and which cookies are used for long term memory of shopping activities of user on our website; such cookies are not necessary for use of our website and are applicable only upon Your consent, and which may be withdrawn in any time
- Third party cookies analytics( CLARITY)
Who uses the information stored in cookies?
||Persists the Clarity User ID and preferences, unique to that site, on the browser. This ensures that behavior in subsequent visits to the same site will be attributed to the same user ID.
||Connects multiple page views by a user into a single Clarity session recording.
||Identifies the first-time Clarity saw this user on any site using Clarity.
||Indicates whether MUID is transferred to ANID, a cookie used for advertising. Clarity doesn't use ANID and so this is always set to 0.
||Indicates whether to refresh MUID.
||Identifies unique web browsers visiting Microsoft sites. These cookies are used for advertising, site analytics, and other operational purposes.
||Used in synchronizing the MUID across Microsoft domains.
The information stored in cookies on our website is used exclusively by us, with the exception of those identified further on as "third party cookies", which are used and managed by external bodies that provide us with services requested by us to improve our services and the user's experience when navigating our website. For more information on third party service providers, as the case may be, you may contact LC WAIKIKI. The main purposes for which these "third party cookies" are used are to obtain statistics on access and to secure payment transactions carried out.
You can control and/or delete, restrict or block cookies from this Website at any time by modifying the configuration of your browser. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a Website and some services and functionalities may not work.
While the configuration of every browser is different, cookies configuration is usually carried out in the "Preferences" or "Tools" menu. For more details about the configuration of cookies in your browser, please check your browser's "Help" menu.
- How can I avoid using cookies on this website?
If you prefer to avoid using cookies on this Website, you will first need to disable cookies in your browser. Please note that if you choose to disable cookies, you will not be able to take advantage of all our features and you may not be able to access certain functions of our Website.
By continuing to use the LC WAIKIKI RETAIL RS doo website you accept our cookies policies.
- Security and Protection of Data
The Company respects the privacy of its customers' personal information and uses its best efforts using the latest technology to ensure the same.
Company implements physical, electronic, technical, and organizational and personnel measures to ensure the security of our system and protection of your personal data. Access to data is restricted only for authorized persons and data is stored and backed up in secure servers.
The data obtained through our website our transferred via SSL (Secure Socket Layer) technology that ensures secure transfer of data.
On pages where you provide your payment details on our website, you will notice that at the far right on the address line (depending on the browser you use) there appears the image of a lock or key and the first letters appearing on this address line change from http to https. If you see this, you can be sure that our website is on secure servers.
Company uses techniques of pseudonymization, encryption and other available measures of protection, as required in accordance with the Law on Personal Data Protection of Republic of Serbia.
- The rights of our customers and visitors regarding their personal data
It is important for us to insure you all your rights in connection with your personal data, reason for which we would like to inform you that, according to the applicable regulations, you have the following rights:
- The right on information about the processing of your personal data and the access right to the personal data: you have the right to obtain from us, at request and free of any charge the confirmation that the personal dat concerning you, are or not collected and processed by us, together with all the other mandatory information provided by law. You can exercise this right by sending us a written and dated request, signed by you and by indicating if you would like to send you this information to a certain address or through a correspondence service.
- The right on rectification and amendment: You have the right that your incorrect personal data be rectified and if necessary to be amended, without delay.
- The right on restriction of the processing: You have the right to request from the us that processing of your personal data be restricted if one of the following conditions is met: (a) the accuracy of the personal data is contested; (b) the processing is unlawful and you oppose the deletion of the personal data and request the restriction of their use instead; (c) we no longer need the personal data for the purposes of the processing, but they are required by you for the submitting, exercise or defence of legal claim; (d) you have objected to the processing and when the verification, whether our legitimate grounds override yours, is ongoing.
Further processing of the personal data which processing is restricted, is possible only upon consent of the data subject, with the exception of their storage or for the purpose of submitting, exercise or defence of the legal claims or for the protection of the rights of another physical or legal person or for exercising of the important public interests.
- The right on data portability: You shall have the right to receive the personal data concerning you, which you have previously provided to the us, in a structured, commonly used and electronically-readable format and have the right to transmit those data to another data controller, under condition: (a) the processing is based on a consent or contract, and (b) the processing is carried out by automated means. The right on data portability includes also right to have the personal data transmitted directly from us to another data controller, where technically feasible. The exercise of the right on data portability shall not apply if processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the us.
- The right to object the processing: You have the right to object, at any time, to processing of its personal data by Company, in case when Company processes such data for the purpose of acquiring of its legitimate interests or interests of third party, including profiling in which case the Company shall no longer process the personal data unless demonstrates that there are legal reasons for processing which override the interests, rights and freedoms of the data subject or are in relation to the submitting, exercise or defence of the legal claims. You shall have the right to object, at any time, to processing of your personal data by us which are processed for direct marketing purposes, including profiling; in that case the Company, shall no longer process the data for such purposes. The Company is obliged to inform data subject on this right to object, at the latest at the time of the first communication with the data subject.
- prohibition of the automated individual decision-making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects to your position, except: (a) is necessary for entering into, or performance of, a contract between the you and Company, or (b) is based on law, by which are determined appropriate protection measures of the data subject’s rights, freedoms and legitimate interests; or (c) is based on the data subject’s explicit consent. In cases (a) and (c) above, the Company is obliged to provide, at least the right of the physical person under control of the Company to participate in decision making, the right of data subject to express his or her point of view and to contest the decision.
- The right on complaint to the Commissioner for information of public importance and personal data protection, address: Bulevar Kralja Aleksandra no. 15, Belgrade: if you consider that processing of personal data is performed contrary to the provisions of the Law. Submitting the complaint to the Commissioner does not affect your right to initiate other procedures of the administrative or court protection.
- The right to address to the court of law: you have the right to address to the court of law for the defence of any rights guaranteed by law that have been violated. Submitting the claim to the court of law does not affect your right to initiate other procedures of the administrative or court protection.
- The right to erasure (”right to be forgotten”): you have the right to request, at any moment, free of charge, the erasure of your personal data if such the personal data are no longer necessary for purposes for which they were collected; the data subject withdraws consent on which the processing is based and where is no other legal ground for the processing; the data subject submitted the objection to the processing; the personal data have been unlawfully processed; the personal data have to be erased for compliance with a legal obligations of the Company; the personal data of minor, who is over 15 years old, have been collected in relation to use of the information society services. In case of cancelling/deleting of private account from our website, the Company shall further process specific data only for statistical purposes in a manner that it is unable the identification of the person and such data will in no way be related to you (data on pages of products which you visited and ordered products, browsing, statistical data..).
- The right to address to the data protection officer at Company: You have the right to address to data protection officer regarding all questions related to processing of your personal data as well for exercising of your rights in accordance with the Law on Personal Data Protection of Republic of Serbia.
- Newsletters, messages and alerts. Opting out of e-Bulletin Subscription
We offer you the right to control whether or not to receive mentioned during your whole experience on our Website.
In this respect, please be informed that, for the purposes of direct marketing (since we initially collect your personal data in the context of the sale of our products through our Website and for purpose of conclusion of the sale and purchase contract) we require your consent to further use your personal data, as offered by you, for our commercial purposes, marketing, sending of newsletters and similar.
In this case, you can always revoke your consent for the personal information used for marketing purposes (e.g. Sending news bulletins or sending offers to your e-mail address), including when we initially collect your personal data or on each of the occasions you receive one of our messages and unsolicited communication.
If you choose to opt out of e-bulletin subscription continuously and at any time, you can easily opt out, free of charge and in an easy manner from the e-bulletin subscription, by clicking on the link "If you do not wish to receive such emails, please click to unsubscribe" appearing in e-bulletins which we send to you on a regular basis or by submitting a notice to email@example.com
with your membership email.
You can get in touch with us using the following contact details:
Data controller: LC WAIKIKI RETAIL RS d.o.o. Belgrade
Kneza Mihaila Street, no. 44, 11000 Belgrade, Serbia
Data protection officer:
address: Kneza Mihaila no. 44, Stari Grad, Belgrade
Contact phone number: 00381 69/4555-319