Privacy policy

Effective as of the: (01-03-2019)

 

This Privacy Policy reflects the obligations taken on by Cottro under the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons 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).

 

This privacy policy is to apply in cases in which Cottro is a data processor in accordance to the General Data Protection Regulation. This Privacy Policy contains guidelines about cookie usage and subscriptions to Cottro’s newsletters. Please read the privacy policy carefully as it informs you about your rights in light of the new privacy regulatons.

 

This Privacy Policy shall inform you on:

  1. The Website’s Privacy Practices when handling your Personal Data
  2. The Website’s Sources on collecting of your Personal Data
  3. The Website’s method of processing of your Personal Data

 

  • 1.1 References

References in this document to:

„Service“, „Website“, „Cottro“, „We“ or „Us“ mean a Data Controller in the context of Regulation (EU) 2016/679, thereinafter referred to as „GDPR“. The Service has all responsibilities of a Data Controler under the GDPR Directive. The Service does not have a Data Protection Officer, nor is obliged to do so under the GDPR Regulations. The Service’s contact information are as follows:

 

Company name:

Cottro

Company registration number:

000-000-000

Company VAT number:

000-000-000

Company Address of Residence:

Jylland, Denmark.

Company e-mail:

contact@cottro.com

 


References to “Buyer” mean any User concluding a sale with Cottro.
References to “You”, “Your” and “User” mean the person, group or other entity utilizing Cottro. References to “Data Subject” mean Users, which are natural persons, to whom the GDPR regulation grants the appropriate rights as described in this Privacy Policy.

References to “Third Parties” mean any person(s) or group(s) falling outside of the scope of regulation of this Privacy Policy.

„Personal Data” means any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

„Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

  • 1.2 Agreement

This Privacy Policy shall inform Users and Data Subjects about the scope of processing of the collected data, based on their informed consensus, fulfillment of contractual obligations entered into between the Data Subject and the Company, as well as pursuing legitimate interests of the Company in regards to processing and collection of the Personal Data. This Privacy Policy is to inform you on the Privacy Practices of the Website and its operator – the Company, while providing you with services under the Terms of Service and the individual Agreements you may enter into. This Privacy Policy shall further inform you of the rights and obligations taken on by the Company for pursuing the Company’s legitimate interests, as well as the rights and obligations in regards to processing of Personal Data that you have given your informed consented to.

  • 1.3 Express Licensing Grant

To the extent as to using the Website, Cottro hereby grants you a non-exclusive and non-transferrable license to use of this Website’s content and services. This license limited to personal use, and is further limited according to any Terms or Agreement that Cottro may stipulate with you in the future. Applicable Licensing Terms may be displayed at an accessible place or visible to you within the Cottro Website.

 

  • 1.4 Abuse of the Service and state authority-issued subpoenas.

While pursuing legitimate interests of the Service, Cottro may disclose your personal information in the range which as necessary under applicable law, in connection with any current or future legal proceedings in order to constitute or defend its legal rights or positions in a civil, penal or criminal matters. The Service, on demand by state authorities and a valid document obliging the Service to disclose your information, the Service may further disclose your personal information upon such request in a range and manner prescribed by applicable law.

 

Cottro has the right, but not the obligation to inquire about potential abuse and/or misbehavior of any User on the Website, and take appropriate action, without exclusion to defending its legal rights in a court of law. The Service further reserves full discretional rights as granted under the Cottro Terms of Service.

 

  1. PRIVACY STATEMENT
  • 2.1 Introduction

    The Service cares about its Users’ privacy. This Privacy Policy shall regulate all means of collection and usage of your Personal Data that Cottro collects and/or processes by any means. The Personal Data processed by the Cottro will be processed lawfully, fairly and in a transparent manner in relation to you; collected or specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with the purposes stated in this Privacy Policy. The Cottro will not process your Personal Data outside the scope of regulation in this Privacy Policy.

    • 2.2 Your Rights

    Your Personal Data is your explicit right. Therefore, in relation to the applicable regulations present, you will have the right to Complaints, Grievances and rights to be informed in case of any changes to the method in which we process you’re Personal Data, as further described below in this Privacy Policy.

     

    • 2.3 Data Collection

    Any Personal Data You entrust us with shall be used in a manner as described in this Privacy Policy. We may use your data for the following purposes:

    • Execution of Agreement with You (for example, if you enter into an Agreement with Cottro, we will use your Personal Data such as your Name, Address of Residence, Contact Number, postal Address or e-mail, to contact you and to fulfill any obligation we have under such Agreement)
    • Handling and Processing your payments (for example, if the Service requires you to submit a payment, you shall be prompted to a secure server, in which you can input your billing details)
    • Providing you with access to your User Account and User Account Settings (for example, if you are a registered User on our Service, you may change certain privacy settings manually, or request from Us to do so on our Customer Support e-mail)
    • Send you occasional Newsletters or other periodic publications you have subscribed to (for example, you find our Offers interesting, and wish to be updated with new products and services that We have to offer)
    • Analyze your preferences and behavior on the Website (for example, we will know the focal points that most Users look to while they’re on the Website, the User preferences when purchasing certain services from us etc., through cookies that we further explain in this Privacy Policy)

     

    • 2.4 Data Processing

    Cottro respects the privacy of its Users. The Website will not treat Personal Data in a manner, which is not in accordance with this Privacy Policy. Any information you provide, shall be provided with your prior explicit consent, and processed in accordance with the purpose, for which it was provided to the Website. You may withdraw your consent at any time, after which we shall delete all your Personal Data from our servers. If we are to provide you with certain services or products under a specific Agreement and you have withdrawn your consent from processing of such data, we will further use this data only for the purpose of fulfilling our contractual obligations towards you.

     

    • 2.5 Data Usage

    The Service will  use your data in order to fulfill the Service’s contractual obligations to you, pursue legitimate interests of the Service and/or State Authorities, as well as use your data in accordance with your informed consent to do so.

    The Service may use your personal data or set preferences in your User account in order to send you occasional newsletters, provided that you have expressed consent to such newsletters. Once you have subscribed from such newsletters, you may unsubscribe at any time.

    The Service’s auxiliary means of financing may be targeted marketing. The Service may use some of the anonymized data collected from your user activity on the Website in order to provide you with targeted advertisements and marketing. Data collected in this way cannot disclose your identity to any third parties, as it consists of behavioral tracking mechanisms while you are using the Cottro.

    The Service cares about providing you with the best user experience. That is why the Service may use in-browser cookies, in order to, for example, log you into your account automatically. This information is stored locally on your device, and you may delete such cookies manually in your browser settings. The Service may use some analytics tools that output anonymized data we use for improving our service to you. These services, as well as their privacy practices shall be listed in section X of this Privacy Policy.

     

    • 2.5.1 Advertisements, Cookies and Clear gif notice.

    Certain information is gathered and stored in log files. This information includes the IP address, browser type, ISP, OS, Date and Time Stamp and Clickstream data. This information does NOT identify individual Users nor can closely distinguish Users. This information is utilized to administer the site and to track Users’ movements across the Website. Cookies are small pieces of data stored locally on the Users’ Browsers. Session ID cookies are used and utilized to maintain Users’ subscriptions and accounts. Information stored in cookies cannot closely distinguish Users. Session Cookies are utilized to improve navigation on our site. Session Cookies expire once you close your browser. Cottro’s Website may include advertisements in various forms. Please note that Cottro does not regulate the advertisement content policy of its Partner Websites, Software or Services. Cottro reserves the right to use cookies and other monitoring technologies to compile anonymous statistics about its Users. Cottro does not believe that this monitoring could lead to disclosing your identity. You can manually change your cookie preferences. Clear gifs are small graphic files embedded in a Website to track the online movements of Users. In contrast to Cookies, Clear Gifs are not stored on your computer. Cottro does not tie online movement or Website usage data to personal information. Google AdSense is a third-party advertising service to provide you with specific targeted advertisements according to your preferences, according to your behavior and searches on the Internet. We use Google Analytics as our third-party statistic provider, which gathers certain information from User behavior on Our Website. The Service uses these tools to follow the Service’s legitimate interest, and believes that such anonymized data cannot reveal a Data Subject’s identity or otherwise be tied to a certain Data Subject. The Service uses these tools namely to introduce a better User Experience to the user, as well as provide the Service with operational information on possible likes or dislikes of Users on the Website, including User Traffic, Website focus points. Advertisements etc.

     

    • 2.5.2 Newsletters and Subscriptions

    If you chose to do so, you may subscribe to our Newsletters, in order to stay informed about the new products and/or service that the Service offers. Once subscribed, you may unsubscribe at any time, at which point all periodic newsletters shall further not be sent out to you. You should find the unsubscribe option directly on the Newsletter’s footer, or contact our Customer Support to be unsubscribed from this option.

     

    • 2.5.3 Opt-outs

    In certain aspect of usage, Users are given the opportunity to opt-out of having their personal information used for certain purposes. All further usage of your personal information provided to you by us shall be subject to your informed consent.

     

    Your personal data is your explicit right. You may opt to deny us access or not providing us this information, manually change your privacy preferences within your User Account, or (in case such manual preferences are not available), contact the Customer Support via the provided e-mail above to opt out of certain privacy settings.

     

    • 2.5.4 Business Applications

    Our Website is powered by Shopify and the variety of apps that it offers for high quality customer service. We may process certain data that you have given to us in order to fulfill our contractual obligations towards you – for example, we will process your Name and Address to provide you with delivery of your desired product. We may use certain Shopify-vetted plugins when providing services to you, such as Oberlo and Eprolo.

     

    1. CONTENT
    • 3.1 Submissions on Cottro

      For the purposes of this section, all forms mutual communications between users or between users and this Website’s administrators, including, but not limited to: comments, ratings or other communications such as text, videos, pictures or other multimedia files on this Website will be referred to as “User Submissions” or simply “Submissions”. User Submissions are a type of content added by (all types of) users, as opposed to the created and displayed content by Cottro. All content uploaded to this Service is to be regarded primarily as a User Submission. Cottro reserves the right, but not the obligation, to start inquiries about possible breaches of these Terms of Service. Cottro does not, in any way, endorse, favor or otherwise approve of any User Submission which is freely uploaded by the Registered Users. Violations of the Terms under which Content may be uploaded may result in removal of the Submission with or without previous notice. Repeated breaches of the Content Terms may result in a part-time or permanent ban of a User from accessing certain functionalities of our Service. Upon sharing your User submission, you retain all proprietary rights. You hereby grant Cottro a Universal, Worldwide, non-Exclusive, Royalty-free, Transferrable License to be used, reproduced, performed, modified, displayed and otherwise manipulate with the User Submission. These licenses granted by you in User Comments are perpetual and irrevocable. The licenses are not valid for User submissions which have or had been deleted by the Users. Please note that this license is only granted to Cottro in order to feature or display some of your user submissions on its Website worldwide. Please note that once shared, Pictures, Profile pictures and other Submissions (picture, text, video, listings, offers, samples, snippets or other multimedia - thereinafter referred to as: User Submissions) are published and Cottro cannot and does not guarantee any confidentiality regarding Your User submission. Furthermore, you hereby warrant that Your User Submission has all the proprietary rights, including intellectual property rights. Upon sharing Your User submission, You retain Your proprietary rights, and further grant Cottro a Universal, Worldwide, non-Exclusive, Royalty-free, Transferrable License to be used, displayed and reproduced in certain areas of this the Cottro Website for promotional or competitive reasons. This license is perpetual and irrevocable. You further agree that You WILL NOT submit material which is subject to intellectual property and/or other proprietary rights of a third party. Cottro Does not endorse any Submission or opinion, recommendation or advice expressed therein.

       

      1. PAYMENT
      • 4.1 Orders and Payment

        In order to purchase a Product from Cottro, certain personal information is required. You should expect to provide contact information (name, e-mail, address) and financial information (billing credentials). This information will be utilized in no other way than billing purposes, contact purposes or authorization, regarding submitted Orders. Upon purchasing a product from Cottro, you may be prompted to an authorized third-party website, in which a contract with your specifics is to be generated. Please note that the specifics in the checkout are to supersede any previous offers made on Cottro Website. Cottro utilizes Third-party credit and debit card processing processors, in order to bill you for ordered Products and/or Services. These Third-party Companies do NOT retain, share, store or use personal information for any other purposes than billing. Upon submitting a successful payment, a sale is concluded. Concluded sales are further governed by the Return and Refund policies, which are available to read on our Website.

         

        1. SECURITY
        • 5.1 Security Measures. Disclaimer on Safety

          Cottro follows accepted industry standards during the process of submission, transmission and acceptation of personal data. No method so far is 100% accurate, but we are committed in caring for the information you share with us in the best way possible.

          This Service, as a legal person bound by ethics and etiquette, will disclose any security breaches which might occur on this Website within 72 hours after having become aware of it to the appropriate supervisory authority as designated under the GDPR.  If such security breaches pose a threat to rights and freedoms of our Users, we shall disclose such a data breach without undue delay, via e-mail.

          All of our employees are kept up to date in regards of privacy practices. Personal and personally-identifiable information is kept in a secure environment. If you have any questions in regards to our Security protocols, please do not hesitate to contact us by means of e-mail, or throughout our Customer Support on our Website.

           

          1. USER RIGHTS
          • 6.1 Rectification

            The Data Subject shall have the right to obtain from the Service, without undue delay, correction of any inaccurate personal data concerning the Data Subject. Taking into account the purposes of the Personal Data Processing, the Data Subject shall have the right to have incomplete personal data completed. The Service shall communicate any rectification or erasure of personal data or restrictions of processing carried out in accordance with this section towards each recipients to whom the personal data has been disclosed, unless rendered impossible or requiring disproportionate effort. In the case the User requests it, the Service shall inform the User about the aforementioned recipients.

            • 6.2 Deletion of Data

            The User shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay from the Cottro database, in case that: - the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed; - the personal data has been processed unlawfully; - the personal data has to be erased in order to achieve compliance with a legal obligation of a Member state to which the Cottro is a subject; - the personal data have been collected in relation to the offer of information society services as per Article 8 of the GDPR. The Service shall communicate any rectification or erasure of personal data or restrictions of processing carried out in accordance with this section towards each recipients to whom the personal data has been disclosed, unless rendered impossible or requiring disproportionate effort. In the case the User requests it; the Service shall inform the User about the aforementioned recipients.

            • 6.3 Restriction of Processing.

            The User shall have the right to obtain from the controller restriction of processing in one of the following cases: - the accuracy of the personal data is contested by the User, for a period enabling the controller to verify the accuracy of the personal data; - the processing is unlawful and the User opposes the erasure of the personal data and requests the restriction of their use instead; - the controller no longer needs the personal data for the purposes of the processing, but they are required by the User for the establishment, exercise or defense of legal claims; - the User has objected to processing in accordance to Article 21 of the GDPR. The Service shall communicate any rectification or erasure of personal data or restrictions of processing carried out in accordance with this section towards each recipients to whom the personal data has been disclosed, unless rendered impossible or requiring disproportionate effort. In the case the User requests it; the Service shall inform the User about the aforementioned recipients.

            • 6.4 Objections
            The User may object to the processing of personal data concerning him or her which is based on pursuing legitimate interests by the Service or sharing of Personal Data based on a state-issued subpoena.

            In cases involving marketing, the User may object to at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing. Where the User objects to processing for direct marketing purposes, the personal data shall no longer is processed for such purposes. Objections may be sent directly to the Service’s Customer Support e-mail address.

            • 6.5 Complaint

            Pursuant to the GDPR regulation, the User may lodge a complaint directly to the Cottro, at the Customer Support’s e-mail address, or lodge a complaint with the appropriate Supervisory Authority the Website is subject to. If you are not sure on to where to address your complaint to the Supervisory Authority, contact us in order to find out more information.

             

                  7 MISCALLENOUS

            • 7.1 Jurisdiction

            If any provision of this Policy is, or is to be found by an appropriate authority, unenforceable under Applicable law, that will not affect the enforceability of any other provisions of these Agreements. No terms set forth herein are constructed in any way or manner in order to limit or otherwise obstruct consumer protection rights. If any such clause exists by applicable law, it shall not affect the enforceability of the remainder of this document.  The parties agree that the applicable law for any disputes arising out of this Agreement is the applicable law in Cottro’s operator’s premises.

             

            • 7.2  Indemnification

            You hereby agree to indemnify and hold Cottro, it’s owner Company, Representatives and Partners harmless from and against any loss, cost, damage and expense, including but not limited to: attorneys' fees and court costs, arising directly or indirectly from Your use of the Cottro’s Website, software or services and/or Your breach of any representation, warranty or restriction contained in this agreement.

             

            • 7.3 Continuity

            Cottro may suspend or discontinue any portion of the whole Service with or without previous notice.

            Cottro may suspend Your access to the Website, provided that a breach under the Website’s Terms of Service has been grounds for termination of Agreement with you

            Every older version of these documents is superseded with the issuing of a renewed version. In case of change of Privacy Policy, we may notify you on our Website and via e-mail. The Service reserves the right to not issue an explanation in the case of modification of these Documents.

             

            • 7.4 Ascent

            These Terms, along with all supplemental documents you have expressed your consent to, without limitation to conclusive means of acceptance, are to be regarded as a single, legally-binding contract between you and Cottro.

             

            • 7.5 Agreement

            This Privacy policy reflects the policy of Cottro in regards to your usage and privacy practices of this Website. They are further intended to inform Cottro Users of the possible results of breaches of these Terms, in regards to using this Website, Software and/or Services. If you have any questions, do not hesitate to contact us via e-mail, post, telephone number or by using our Online Support Service.

             

             

             

            Section X – Personal Data that may be collected by third Parties. Personal Data shared with Third Parties

             

            The Service may utilize certain data concerning the User, which may not be gathered from the User directly. The Service may further use these third party services in order to gather certain data on the user’s behavior. Such data, the purpose for processing, and the privacy practices of these Third Parties are listed in the table below:

             

            #:

            Name of Service and Website:

            Policies on Privacy:

            Services used

            Purpose for processing:

            Lawful basis for processing:

            Type of Data

            1.

            Google

            (Google, Inc. – U.S.)

            Privacy Policy – Opt Out

            Google AdSense

            Google AdWords

            Google Analytics

            Traffic and User behavior information, Advertisement tools

            Legitimate interest

            Anonymized

            2.

            Facebook

            (Facebook, Inc.- U.S.)

            Privacy Policy

            Facebook Ads

            Facebook Analytics

            Traffic and User behavior analytics, Advertisement tools

            Legitimate Interest

            Anonymized

            3.

            Bing

            (Microsoft Corporation – U.S.)

            Privacy Policy

             

            Bing Ads

            Traffic and User behavior analytics, Advertisement Tools

            Legitimate interest

            Anonymized

            4.

            Oberlo

            (Shopify Inc., U.S.)

            Privacy Policy

             

            Oberlo dropshipping services

            Processing of Orders

            Legitimate Interest

            Name, Address, e-mail and telephone number