Privacy Policy

KLICKL EUROPE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ, incorporated on 21 August 2023 (KRS number 0001053580), whose registered office is at ul. BARTYCKA 22B / 21A, 00-716 WARSZAWA, poczta WARSZAWA, kraj POLSKA, and our partners (hereinafter, KLICKL, “we”, “us” or “our”) are committed to protecting and respecting your privacy.

This Privacy Policy describes how KLICKL EUROPE Limited (or KLICKL) collects and processes your personal information through the KlicklX websites and applications that reference this Privacy Notice. KlicklX refers to an ecosystem comprising mobile applications, clients and other applications that are developed to offer KlicklX Services, and includes independently-operated platforms and clients within the ecosystem. “KlicklX Operators” refer to all parties that run KlicklX, including but not limited to legal persons, unincorporated organisations and teams that provide KlicklX Services and are responsible for such services. “KlicklX” as used in this Policy includes KlicklX Operators. KlicklX operates both as a data controller and data processor.

This Privacy Policy applies to all platforms, websites, and departments of KlicklX and KlicklX Operators. By using KlicklX Services, you are consenting to the collection, storage, processing and transfer of your personal information as described in this Privacy Policy.

KLICKL Europe (legal entity registration number 1053580 with registered office address 22B Bartycka Street, Unit 21A, Warsaw, Post code 00-716 Warsaw Poland) is the Data Controller for personal information collected and processed in connection with provision of KlicklX Services.

1. What Personal Information About Users Does KlicklX Collect?

KlicklX collects your personal information in order to provide and continually improve our products and services. Here are the types of personal information we collect:

Information you give us:

We receive and store any information you provide in relation to KlicklX. You can choose not to provide certain information but then you might not be able to use some KlicklX Services. Examples of information that you give us include:

• Name
• E-mail Address
• Gender
• Date of birth
• Home address
• Nationality
• Country code
• Other information to help us identify you

Automatically collected information:

We automatically collect and store certain types of information about your use of KlicklX Services including your interaction with content and services available through KlicklX Services. Like many websites, we use cookies and other unique identifiers and we obtain certain types of information when your web browser or device accesses KlicklX Services. Examples of the information we collect and analyse include:

• The Internet protocol (IP) address used to connect your computer to the internet
• Login, e-mail address, password and location of your device or computer
• KlicklX Services metrics (e.g., the occurrences of technical errors, your interactions with service features and content, and your settings preferences) which include version and time zone settings and transaction history

Information from other sources:

We may receive information about you from other sources such as credit history information from credit bureaus, which we use to help prevent and detect fraud.

2. Can Children Use KlicklX Services?

KlicklX does not allow anyone under the age of 18 to use KlicklX Services.

3. For What Purposes Does KlicklX Process My Personal Information?

We process your personal information to operate, provide, and improve the KlicklX Services that we offer our users. These purposes include:

• Transaction services: We use your personal information to take and handle orders and to process payments, and communicate with you about orders and services, and promotional offers.
• Provide, troubleshoot, and improve KlicklX services: We use your personal information to provide functionality, analyse performance, fix errors, and improve the usability and effectiveness of KlicklX services.
• Recommendations and personalisation: We use your personal information to recommend features and services that might be of interest to you, identify your preferences, and personalise your experience with KlicklX services.
• Comply with legal obligations: In certain cases, we collect and use your personal information to comply with laws and regulations. For instance, we collect bank account information for identity verification and other purposes.
• Communicate with you: We use your personal information to communicate with you in relation to KlicklX services.
• Fraud prevention and credit risks: We process personal information to prevent and detect fraud and abuse in order to protect the security of our users, KlicklX Services and others. We may also use scoring methods to assess and manage customer specific risks.
• Purposes for which we seek your consent: We may also ask for your consent to process your personal information for a specific purpose that we communicate to you. When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop processing of your data for that purpose.

4. What About Cookies and Other Identifiers?

We use cookies and similar tools to enhance your user experience, provide our services, and understand how customers use our services so we can make improvements. To enable our systems to recognise your browser or device and to provide KlicklX Services to you, we use cookies. We use operational cookies and similar tools (collectively, "cookies") to provide our services, for example:

• Recognising you when you sign-in to use our services.
• Providing customised features and services.
• Displaying features and services which might be of interest to you, including ads on our services.
• Preventing fraudulent activity.
• Improving security.
• Keeping track of your preferences such as currency and language.
• We also use cookies to understand how users use our services so we can make improvements.

The settings on your browser will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, how to disable and remove cookies, and when cookies will expire. Operational cookies allow you to take advantage of some of KlicklX's essential features. If you block or otherwise reject operational cookies through your browser settings some features and services may not work.

5. Does KlicklX Share My Personal Information?

Information about our users is an important part of our business and we are not in the business of selling our users' personal information to others. KlicklX shares users' personal information only as described below and with the subsidiaries or affiliates of KlicklX that are either subject to this Privacy Notice or follow practices at least as protective as those described in this Privacy Notice.

• Third party service providers: We employ other companies and individuals to perform functions on our behalf. Examples include analysing data, providing marketing assistance, processing payments, transmitting content, and assessing and managing customer risk. These third-party service providers have access to personal information needed to perform their functions, but may not use it for other purposes. Further, they must process the personal information in accordance with this Privacy Notice and as only permitted by applicable data protection laws.
• Business transfers: As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, user information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice (unless, of course, the user consents otherwise). Also, in the unlikely event that KlicklX or substantially all of its assets are acquired, user information will be one of the transferred assets.
• Protection of KlicklX and others: We release account and other personal information when we believe release is appropriate to comply with the law or with our regulatory obligations; enforce or apply our Terms of Use and other agreements; or protect the rights, property or safety of KlicklX, our users or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction.

6. International Transfers of Personal Data

KlicklX may transfer your data outside of the EU. KlicklX puts in place suitable safeguards to ensure that such transfer is carried out in compliance with applicable data protection rules. Where KlicklX transfers personal data to affiliates or service providers, KlicklX relies on the standard contractual clauses approved by the European Commission.

7. How Secure is My Information?

We design our systems with your security and privacy in mind. We work to protect the security of your personal information during transmission by using encryption protocols and software. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your personal information. Our security procedures mean that we may ask you to verify your identity before we disclose personal information to you. It is important for you to protect against unauthorised access to your account password. We recommend using a unique password for your KlicklX account that is not utilised for other online accounts. Be sure to sign off when you finish using a shared computer.

8. What About Advertising?

We may share your personal information with our marketing partners for the purposes of targeting, modelling, and/or analytics as well as marketing and advertising.

9. What Information Can I Access?

You can access your information, including your name, address, payment options, profile information, and transaction history in the "Your Account" section of the website.

10. What Choices Do I Have?

If you have any questions or objection as to how we collect and process your personal information, please contact info@klickl.eu. When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop any further processing of your data for that purpose. In addition, subject to applicable law, you have the right to request access to, correct, and delete your personal data, and to ask for data portability. You may also object to our processing of your personal data or ask that we restrict the processing of your personal data in certain instances. If you wish to do any of these things, please contact info@klickl.eu.

11. How Long Does KlicklX Keep My Personal Information?

We keep your personal information to enable your continued use of KlicklX Services, for as long as it is required in order to fulfil the relevant purposes described in this Privacy Notice, as may be required by law such as for tax and accounting purposes, or as otherwise communicated to you.

12. EU GDPR and Polish Data Protection Law - Legal Basis

The EU GDPR and Polish data protection, namely the Personal Data Protection Act of 10th May 2018, require a legal basis for our use of personal information. Our basis varies depending on the specific purpose we use personal information. We rely on:

• Performance of a contract: When we provide you with products or services or communicate with you about them. This includes when we use your personal information to take and handle orders and process payments.
• Our legitimate business interests and the interests of our users: When we detect and prevent fraud and abuse in order to protect the security of our users, ourselves, or others.
• Your consent: When we ask for your consent to process your personal information for a specific purpose that we communicate to you. When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop processing of your data for that purpose.
• Compliance with a legal obligation: When we use your personal information to comply with laws. For instance, we collect bank account information for identity verification and anti-money laundering purposes.
• These and other legal bases depend on the purpose for which we use personal information.

13. Your Rights as a Data Subject

Under certain circumstances, by law you have the right to:

• Request access to your personal information: (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you, the basis of our processing and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you: This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information: This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information: Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information: This enables you to ask us to suspend the processing of personal information about you, for example, where the processing is unlawful or no longer lawful, if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party: If you want to review, verify, correct, or request erasure of your personal information, object to processing your personal data, or request that we transfer a copy of your personal information to another party, please contact our Data Protection Officer at info@klickl.eu.

No fee is usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

14. Right to Withdraw Consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Officer at info@klickl.eu. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

15. Conditions of Use, Notices and Revisions

If you choose to use KlicklX Services, your use and any dispute over privacy is subject to this Notice and our Terms of Use. If you have any concerns about privacy at KlicklX, please contact us with a thorough description, and we will try to resolve it. You also have the right to contact your local Data Protection Authority.

Our business changes constantly, and our Privacy Notice will change also. You should check our websites frequently to see recent changes. If you do not agree with the revised content, you shall stop accessing KlicklX immediately. When an updated version of the Privacy Policy is released, your continued access to KlicklX means that you agree to the updated content and agree to abide by the updated Privacy Policy. Unless stated otherwise, our current Privacy Notice applies to all information that we have about you and your account.

Links

There may be links from our Site to other sites and resources provided by third parties. This Privacy Policy applies only to our Site. Accessing those third-party sites or sources requires you to leave our Site. We do not control those third-party sites or any of the content contained therein, and you agree that we are in no way responsible or liable for any of those third-party sites, including, without limitation, their content, policies, failures, promotions, products, services or actions and/or any damages, losses, failures or problems caused by, related to or arising from those sites. We encourage you to review all policies, rules, terms and regulations, including the privacy policies, of each site that you visit.

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