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Last Modified: 12. April 2024.
1. INTRODUCTION
Sugar Petals Kft.(“Company”) respects your privacy. This Privacy Policy sets forth Company’s policy with respect to the types of information we may collect from you or that you may provide when you visit sugarpetalsbyildiko.com and courses.sugarpetalsbyildiko.com(“the Website”), including any content, services, functionality, mobile applications, downloadable materials, and courses (“the Services”). If you do not agree with our Privacy Policy, your choice is to not use our Website. By accessing or using this Website, you agree to this Privacy Policy and the Terms of Use found here: courses.sugarpetalsbyildiko.com/terms&conditions
2. CHILDREN UNDER THE AGE OF 16
All website users must be at least 16 years of age. If we learn we have received information from a child under 16 we will delete the information. If you have reason to believe that a child under the age of 16 has provided Personal Data to us through the Website or Services, please contact us and we will endeavor to delete the information from our database. If we learn a user is under 16 years of age, we will not disclose any personal information to any third parties unless the user has given opt-in consent. If you have reason to believe that a user is under 16 years of age, notify the Company in order to prevent disclosure of any personal data without opt-in consent.
3. WHEN WE COLLECT INFORMATION FROM YOU
We collect data and process data when you access our Website, fill out forms on our Website, register, make a purchase, sign up for our newsletter, respond to a survey, surf the Website, or use or view our Website via your browser’s cookies.
4. WHAT TYPES OF INFORMATION WE COLLECT FROM YOU
A.Voluntary Information
A.When you visit our Website or use our Services we collect certain types of information from you. This includes your name, email address, mailing address, phone number, credit card information, age, sex, marital status, race, nationality, or other information you provide to us.
B.Automatic Data Collection
A.We also collect information automatically through cookies and other tracking technologies such as information about your internet connection, your IP address, traffic and location data, logs and other information. The information we automatically collect helps us to improve our Website and deliver a better service.
C.The categories of consumer data we have collected within the past 12 months includes name, address, email address and credit card information.
5. HOW WE COLLECT INFORMATION FROM YOU
The data controller is Sugar Petals Kft. The technologies we use for automatic data collection include “cookies.” Cookies are small files placed on the hard drive of your computer that enables the website or service provider’s systems to recognize your browser and remember certain information. We use functionality cookies to recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. We use advertising cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. Our Company sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our Website. You may refuse to accept browser cookies by activating the appropriate setting in your browser, but if you do, you may not be able to access certain parts of our Website or Services. We also use flash cookies or web beacons for automatic data collection. You may also provide information that is public or displayed on public areas of the Website, or transmitted to other users of the Website or third parties (“User Content”). Your User Content is transmitted to others at your own risk.
6. HOW WE USE YOUR INFORMATION
Processing of your information is necessary for the purpose of legitimate interests and does not infringe on any fundamental rights and freedoms. Some of those legitimate interests include: direct marketing, processing of client data. We use your information to understand and store information about visitor’s preferences, to compile aggregate data about site traffic and site interactions, to provide you with information, products, or services that you request from us or that we think you may like, to provide you with notices about your account, to carry out billing and collection, for customer support, for marketing purposes, and in any other way we describe when you provide information to us. We do not use automated decision-making in processing your personal information for some services and products. You can request a manual review of the accuracy of an automatic if you are unhappy with it. We do not sell personal information or consumer data for monetary gain or valuable consideration
7. THIRD PARTY DISCLOSURES
Some content or applications on the Website are served by third parties, such as advertisements. We do not control third parties’ tracking technologies. You should consult the privacy policies of any such third party for more detailed information on their practices. Our Company Website contains links to other websites. Our privacy policy applies only to our Website, so if you click on a link to another website, you should read their privacy policy.
8. HOW WE DISCLOSE YOUR INFORMATION
A.We may disclose aggregated information about our users and information that does not identify any individual without restriction.
B.We do not disclose personal information that we collect or you provide as described in this Privacy Policy to third parties.
C.We use your provided data to prevent fraudulent purchases by sharing your data with credit reference agencies.
D.We will release information when it is appropriate to comply with the law or enforce our site policies.
E.Do Not Track Policy: Our site honors Do Not Track (“DNT”) browser settings. We do not track your online browsing activity on any other online service.
F.We do not transfer personal data collected from you to third party processors located internationally. Please be aware that such countries may not have the same level of data protection; however, our collection, storage and use of your personal data will continue to be governed by this Privacy Policy.
9. HOW WE STORE AND PROTECT USER INFORMATION
A.Company securely stores your data on secured servers. We have implemented security measures designed to protect your visit to the Website. These include:
A.All payment information is encrypted.
B.All information you provide to us is stored on our secure servers behind firewalls.
C.We use regular Malware Scanning.
D.No transmission over the internet or email is completely secure or error free. Please keep this in mind when disclosing personal information over the internet.
B.We will keep your data for 2 years. Once this time period has expired, we will delete your data.
10. YOUR CALIFORNIA PRIVACY RIGHTS
A.If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/ccpa
B.Under the CCPA, California residents have the right to opt-out of the sale of personal information about them or their household, such as their name, postal or email address, and other personal identifying information. The right is subject to certain exceptions. For example, it does not apply to information that we share with certain third-party service providers so they can perform business functions for us or on our behalf. You may opt out emailing flowers@sugarpetalsbyildiko.com. C.In the preceding twelve months, we have not sold personal information. Our policy is that we do not and will not sell your personal information, unless you give us your consent or direct us to do so.
11. RIGHT TO OPT OUT
You have agreed to receive marketing material from the Company and have consented to the Company disclosing your information to third parties for marketing purposes. You may opt out at any time. If you no longer wish to be contacted for marketing purposes, please click unsubscribe in any email you receive.
12. YOUR DATA PROTECTION RIGHTS
A.The Right to be Informed: This means anyone processing your personal data must make clear what they are processing, why, and who else the data may be passed to.
B.The Right to Access: This is your right to see what data is held about you by a Data Controller.
C.The Right to Rectification: You have the right to have your data corrected and amended if what is held is incorrect in some way. You can request that we correct any information that you believe is inaccurate or request that we complete information that you believe is incomplete.
D.The Right to Erasure: Under certain circumstances you can ask for your personal data to be deleted. This is also called “The Right to be Forgotten.” This would apply if the personal data is no longer required for the purposes it was collected for, or your consent for the processing of that data has been withdrawn, or the personal data has been unlawfully processed.
E.The Right to Restrict Processing: This gives you the right to ask for a temporary halt to processing of personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.
F.The Right of Portability: You have the right to ask for any data supplied directly to the Data Controller by you, to be provided in a structured, commonly used, and machine-readable format. You may request copies of your personal data from us. You may request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions. We may charge a small fee for this service or for any copies requested.
G.The Right to Object: You have the right to object to further processing of your data which is inconsistent with the primary purpose for which it was collected, including profiling, automation, and direct marketing.
H.Rights in Relation to Automated Decision-making and Profiling: You have the right not to be subject to a decision based solely on automated processing.
I.Right Not to be Subject to Discrimination for the Exercise of Rights: The Company will not refuse goods or services to individuals who exercise their consumer rights. If you would like to exercise these rights, please contact us at flowers@sugarpetalsbyildiko.com.
13. CHANGES TO PRIVACY POLICY
The date the Privacy Policy was last revised is identified on the first page of the Privacy Policy. We reserve to update this policy and if we make material changes to how we treat our users’ personal information we will notify you by email. You are responsible for periodically visiting our Website and Privacy Policy to check for any changes.
14. CONTACT
You may send us an email to inquire about our Privacy Policy or to request access to, correct or delete any personal information that you have provided to us at: Sugar Petals Kft. Ildiko Miniska-Karlsson 1067 Budapest, Eotvos u. 36. flowers@sugarpetalsbyildiko.com You may reach our Data Protection Officer by sending an email to flowers@sugarpetalsbyildiko.com.
15. COMPLAINTS
Should you wish to report a complaint or if you feel that our Company has not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s office (if an individual located in the United Kingdom) or the European Data Protection Board.
16. INDIVIDUALS LOCATED WITHIN THE UNITED KINGDOM
A.Restricted Transfers:
Our Company may make a restricted transfer if the receiver is located in a third country or territory or is an international organization, covered by UK “adequacy regulations.” If there are no adequate regulations about the country, territory or sector for the restricted transfer, our Company should then find out whether you can make the transfer subject to ‘appropriate safeguards’ as listed in the UK GDPR. Before we rely on an appropriate safeguard to make a restricted transfer, we must be satisfied that the data subjects of the transferred data continue to have a level of protection essentially equivalent to that under the UK data protection regime. We do this by undertaking a risk assessment, which takes into account the protections contained in that appropriate safeguard and the legal framework of the destination country (including laws governing public authority access to the data). If our assessment is that the appropriate safeguard does not provide the required level of protection, we will include additional measures.
Appropriate safeguards may be:
(1) A legally binding and enforceable instrument between public authorities or bodies;
(2) binding corporate rules as defined in Article 47 of the UK GDPR;
(3) a contract incorporating standard data protection clauses recognized or issued in accordance with the UK data protection regime; (4) a code of conduct approved by the ICO;
(4) Certification under an approved certification scheme;
(5) a bespoke contract governing a specific restricted transfer which has been individually authorized by the ICO; or
(6) Administrative arrangements between public authorities or bodies. If none of the criteria above apply for the transfer, we may still make the transfer if the transfer is covered by an ‘exception’ set out in Article 49 of the UK GDPR.
B.CHILDREN UNDER THE AGE OF 13:
All website users located in the United Kingdom must be at least 13 years of age. If we learn we have received information from a child under 13 we will delete the information. If you have reason to believe that a child under the age of 13 located in the United Kingdom has provided Personal Data to us through the Website or Services, please contact us and we will endeavor to delete the information from our database. If we learn a user is under 13 years of age, we will not disclose any personal information to any third parties unless the user has given opt-in consent. If you have reason to believe that a user is under 13 years of age, notify the Company in order to prevent disclosure of any personal data without opt-in consent.
C.Local Representative in United Kingdom: We do not either offer goods or services to individuals in the UK; or monitor the behavior of individuals in the UK
We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.
Where we are required to collect personal data by law, or under the terms of the contract between us and you, if you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don't provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
Customer Data:
We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
User Data:
We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
Technical Data:
We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
Marketing Data:
We process this data to enable you to partake in our promotions such as competitions, prize draws and free giveaways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations(PECR), we may send you marketing communications from us if
you made a purchase or asked for information from us about our goods or services or you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since.
Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by emailing us via the contact us form at any time.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc
We may have to share your personal data with the parties set out below:
Online Course platform provider Zenler.com who will be data processor of your data. We have entered into a data processing addendum with Zenler to process your data. Other companies in our group who provide IT and system administration services and undertake leadership reporting. Service providers who provide cloud infrastructure, video hosting, live video platforms, email provider, IT and system administration services.
Our Online course platform Zenler provider based in the UK is our data processor and we have entered into data processing agreement for the processor to protect your personal data. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. Where we use providers based in the United States (for example Amazon, Sendgrid) we may transfer data to them where we have signed data processing addendums for the provider to provide protection of data shared between the Europe and the US.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
We may include links to third-party websites, addons and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
By providing us with your data, you warrant to us that you are over 13 years of age.