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Privacy and Cookie Policy

PRIVACY POLICY

This policy is designed to explain to our customers how we protect the personal data that we

collect and to inform them of their rights and obligations. We make sure to comply with the most

current applicable laws and regulations of the Republic of Latvia when processing personal data.

This Privacy Policy does not apply to the data processing practices of third companies and we

kindly ask you to always consult the explanations provided by such companies regarding the

processing of personal data when using their services.

GENERAL TERMS:

Regulator SKARULE IK , reg. No. 40002190847, legal address: Volguntes 33A-10, Riga, Latvia,

LV-1046 (hereinafter referred to as  SKARULE).

Regulator’s contact details in relation to the processing of personal data - SKARULE IK , reg. No.

40002190847, legal address: Volguntes 33A-10, Riga, Latvia, LV-1046, studio address:

Kronvalda bulvaris 4, Riga, Latvia, LV-1010, telephone: +37126354535, e-

mail: info@skarule.com

Personal data – any information related to an identified or identifiable natural person.

Processing of personal data – operations with personal data with or without the use of automated

means, such as collection, registration, organization, structuring, storage, customization or

transformation, retrieval, viewing, use, disclosure, transmission, distribution of or otherwise

making available, restricting access to, deleting or destroying.

Privacy policy – a set of applicable measures implemented to ensure the privacy and protection

of personal data in relation to:

• Natural persons – Customers and other users of the services provided (including potential, past

and present) as well as third parties who receive the information from or provide the information

to the SKARULE in connection with the provision of the services to natural persons.

•Visitors to SKARULE stores, offices, warehouses and other structural subdivisions, including

individuals subject to video surveillance;

•Visitors to the Internet and/or mobile and/or social sites maintained by SKARULE.

Customer - a natural person using the services provided by the SKARULE, regardless of how

such services could be provided: in person, via the Internet, mobile applications, social networks,

over the telephone, etc.

Website - Internet site developed by SKARULE, where services to the Customers may be

provided. Website is intended for use by individuals aged 13 and over.

Services - the Services provided to the SKARULE Customers in accordance with the wishes and

the volume as expressed by the Customers and as defined and described by the SKARULE

policies within the offered scope of Services, as well as corresponding to the restrictions set forth

in the binding regulatory enactments of the Republic of Latvia.

To provide its Services and sales of its goods to the Customers, SKARULE may conduct, but is

not limited to, the following activities:

- Customer identification;

- Preparation and ratification of Customer agreements and accompanying documentation;

- Delivery of goods and/or Services to the Customer;

- Warranty obligations;

- Customer services, incl. handling suggestions, claims, and requests;

- Activities aimed at the improvement of the Goods and Services provided to the Customer, incl.

attraction of new Customers, Customer loyalty programs;

- Promotion and distribution of goods and Services (for commercial purposes);

- Billing management;

- Communication with the Customer for administrative purposes, incl. the purpose of ensuring

that the applicable obligations set out in the binding legal acts of the Republic of Latvia are met

by SKARULE;

- Debtor management, incl. monitoring of solvency, possible monitoring of debts and recovery;

- Internet activities, incl. maintaining a presence on social networks, development and

improvement of mobile applications.

SKARULE IS CONDUCTING AND PLANNING THE FOLLOWING DATA PROCESSING

ACTIVITIES:

- Data analysis and reporting for statistical purposes;

- Data processing for quality assurance and risk management;

- Data processing for current business and planning purposes;

- Processing of data collected through market and public opinion polls;

- Processing of data collected through customer surveys;

- Provision of data information to the state (public) regulatory institutions (e.g. supervisory

authorities) in accordance with the applicable regulatory framework.

SKARULE DATA PROCESSING ACTIVITIES ARE CARRIED OUT FAIRLY AND

LAWFULLY IN ACCORDANCE WITH THE FOLLOWING LEGAL PRINCIPLES:

- Following the Customer’s request, for the purpose of concluding and fulfilling the Customer’s

agreement;

- In accordance with the Customer’s consent;

- Realizing the legitimate interests arising from the existing obligations of SKARULE before its

Customer, regulated by the agreement or by legislation;

- Fulfilling the obligations set forth in the binding regulatory enactments;

- Personal data is collected and processed for the specific purposes only;

- SKARULE do not knowingly collect personal information about children.

THE PROCESSING OF PERSONAL DATA IS CARRIED OUT WITHOUT THE

ACCUMULATION OF EXCESSIVE DATA, ENSURING ITS ACCURACY, ADEQUACY OF

DATA RETENTION PERIOD AND THE RIGHTS OF THE CUSTOMER

- Personal data is collected for the specific purposes only and strictly in accordance with the

applicable laws;

- The processing of personal data shall be carried out in accordance with the organizational,

financial and technological capabilities and resources reasonably available to SKARULE, also

taking into account the development of modern technology.;

- In case of automated decision making, the Customer shall be informed in accordance with

regulatory enactments. The Customer shall have the right to object to automated decision

making, but in some cases such objection may limit the Customer's potential right to peruse the

facilities made available to them.

THE DATA SHALL BE RETAINED AS LONG AS AT LEAST ONE OF THE GROUNDS

LISTED BELOW CONTINUES TO EXIST:

- There is a valid agreement with the Customer;

- The validity of Customer's consent to personal data processing has not expired, unless the

purpose of personal data processing is otherwise due;

- There is a legal obligation to retain data;

- There is a need to ensure the realization of legal interests dictated by the laws and regulations

applicable to the SKARULE and/or the Customer.

- The retention terms of the Personal Data have not been specified,

- Until Customer's personal data is deleted.

PERSONAL DATA SHALL BE PROCESSED IN ACCORDANCE WITH THE FOLLOWING

CUSTOMER'S RIGHTS:

- In compliance with any and all applicable laws and regulations;

- In compliance with the right to receive information related to the processing of Customer's data,

the right to request rectification, correction, alteration, deletion of Customer's personal data, the

right to refuse to receive commercial information, the right to request data transfer and other legal

/ contractual rights;

- The exercise of the above rights may be restricted if the processing of personal data is required

in accordance with SKARULE obligations under applicable laws and regulations and in the public

interest.

THE CUSTOMER MAY EXERCISE THEIR RIGHTS BY SUBMITTING A REQUEST:

- In written form to any SKARULE store attaching proof of identity and details of the contact

address;

- By electronic mail to info@skarule.com having signed such request with their secure electronic

signature.

A reply is to be provided to the contact or email address specified in the request. Technological

and logistical safeguards are applied to the protection of personal data, which, taking into

account organizational, financial and technical resources, are found to be feasible via the

assessment of potential risks. SKARULE is constantly developing security processes aimed at

protection of data, both through the education of its employees and taking physical steps to

protect the information, IT infrastructure, internal and external networks, and the company’s structural

subdivisions from unauthorized data access.

THE EXCHANGE OF PERSONAL DATA MAY BE NECESSARY IN SPECIFIC CASES,

SUCH AS:

When Services are provided in collaboration with partners (e.g. courier, billing service providers);

for security and protection purposes (for example, IT security administration); for general and

contract administration purposes (e.g. submission of statistical data, organizational and financial

management, organization of events); submission to supervisory and public authorities (e.g. law

enforcement agencies); for debt collection purposes or for the protection or the enforcement of

legal interests.

The above list is not exhaustive as in some cases personal data may also be exchanged upon

Customer's consent to collection and processing of anonymized data and in similar cases.

SKARULE website may use cookies that the customer has the right to refuse to use, however,

we point out that in some cases full provision of the services offered on the website may be

affected. You can read our Cookie Policy here. If the Website contains links to the third-party

websites, SKARULE is not held responsible for accessing such websites, so we encourage

reading the third party website use and privacy policies separately.

SKARULE reserves the right to modify and expand this Privacy Policy by publishing the updated

version on the SKARULE website.

If you have any inquiries about this Privacy Policy or about how we process your personal data,

please contact us using the contact details above or the contact details listed in the Contacts

section of our website.

If the Privacy Policy is translated into other languages, in the event of a dispute the Latvian

version of this Privacy Policy shall prevail.

COOKIES POLICY

COOKIES TYPES AND USE

1. SKARULE utilizes Internet analytical services powered by Google Analytics to help analyze

the use of www.skarule.com, including understanding visitor activity on www.skarule.com for the

purpose of assisting SKARULE in their attempts to improve and make the website more user-

friendly and operational. The use of these services requires separate user consent.

2. The cookies collect information about personal use of the www.skarule.com website, such as

the standard log entry information (connection time, duration, IP address) as well as the

anonymous information about user activities on the website.

3. To avoid repeated requests for consent each time the visitor returns to the website,

SKARULE also utilizes cookies recording whether the user has already consented to the use of

cookies on www.skarule.com or not.

USE AND STORAGE OF COOKIES DATA

4. According to Google Inc. Terms of Service and Google Analytics Terms of Service, Google will

use the information collected to evaluate the usability of SKARULE website and to report on

user activity on the website.

5. The cookies on SKARULE website neither provide for nor allow any third party to find or

collect any personally identifiable information about the www.skarule.com visitors.

6. For the preservation of anonymity before the information collected by Google Inc. is stored, in

accordance with the request of SKARULE the last octet of the user’s IPv4 address is deleted and

the last 80 bits of IPv6 address are set to zero.

7. The collected information is sent to and stored on Google Inc. servers located in many

countries around the world. The information may be processed on a server located outside

Latvia or the European Union.

OPTING OUT OF COOKIES

8. The user may opt-out of the Google Analytics cookies by downloading and installing the

Google Analytics Opt-out Browser Add-on. This add-on communicates with the Google Analytics

JavaScript (ga.js) to indicate that information about the visit to the website is not to be sent to

Google Analytics.

9. The user can also change their browser settings to opt-out of new cookies, turn off existing

ones, or simply notify when the new cookies are sent to the user device. Read more on

http://www.allaboutcookies.org/.

CHANGES TO THE POLICY

10. SKARULE Cookie Policy is subject to change when deemed necessary. All changes to the

Cookie Policy will be published by SKARULE on www.skarule.com, along with the specific notice

of such changes. Previous versions of the Cookie Policy will be archived by SKARULE so that

they could be reviewed if necessary.