Privacy policy

1. Introduction

1.1. MB KO Group respects your privacy. We strive to build confidence of the Customers and Visitors in this connection. Therefore, the company collects, stores, uses and discloses your personal details, including Personal information provided while using the e-commerce platform (system) managed by the Seller, that operates in the Internet space and can be accessed at comflowgroup.com only as described in this Privacy policy.

1.2. The Seller ensures safety and confidentiality of Personal information of the Visitors and Customers provided by them while using the measures of the Website in accordance with the terms and conditions set out in the Privacy policy. Privacy policy forms and integral part of the Rules. It is intended to protect Personal information of the Customers and Users of the Website against unauthorized use.

1.3. The Seller is a controller of personal data registered in the state register of Controllers of personal data. When acting as a controller of personal data the Seller shall have the right to process Personal data of the Visitors and Customers, including, but not limited to, for the purposes of e-commerce, direct marketing and other purposes, under the procedure specified in this Privacy policy and (or) in any other document of the Rules.

1.4. You confirm by transfer of your Personal information via the Website that you agree with the Privacy policy and the Rules, you also confirm that your Personal information can be processed under the procedure stipulated in the Privacy policy. Please note that the Privacy policy is binding on any person who visits the Website and (or) acquires Goods using the measures installed in the Website and uses the Website and its part as well as any other services, tools or any content of the Website in a different manner. If you disagree with this Privacy policy, you are prohibited from using the Website and any services, tools that are accessible in the Website or any other content of the Website.

1.5. The Seller may process your Personal information not only in the state in which such information was collected but also in other states that apply less strict legal acts that govern processing of Personal information. The Customer also understands and consents that Personal information and any other Customer related information collected by the Seller can be stored both in the Republic of Lithuania and in any other country. By his/her use of the Website the Customer agrees with transfer of aforementioned information outside the Customer‘s country.

1.6. If you wish to notify us on infringement of the Privacy policy, should you have inquiries, claims or should you need our assistance regarding interpretation of the Privacy policy or its application, please contact us by email info@comflowgroup.com or by post at the address MB KO Group, Raudondvario pl. 78, Kaunas, Lithuania, 47182. We will respond to your written inquiries within 14 (fourteen) calendar days from the date of receipt of the inquiry.

2. Terms

2.1. The terms and sayings used in the Privacy policy and commencing with a capital letter are defined in the procedure of use of the Website, in other documents of the Rules and (or) in other requirements and instructions that are accessible in the Website. Except when the terms used in this document, including its preamble, that commence with a capital letter have the following meaning:

2.1.1. Personal data – Personal information about the Visitor and (or) the Customer who is a natural person. Personal data are considered to be any information associated with a natural person – a data entity whose identity is known or can be directly or indirectly determined using such data as personal number, one or several person specific characteristics of physical, physiological, psychological, economic, cultural or social nature.

2.1.2. Cookies – small text files sent to your browser and stored in your computer, phone or other device. They are designed to help websites remember your actions in the past.

3. Anonymity and automatic processing of anonymous information

3.1. Measures installed in the Website make it possible to use the Website anonymously, i.e. to use the Website in the way that allows collection of Anonymous information only with help of the Website measures. The Website can be used anonymously both by the Visitors and the Customers who are not logged to their Account. You can use the Website anonymously until you will decide otherwise or until you will decide to perform actions in the Website that require disclosure of your Personal information (e.g. to create an account or to log in to your Account, to place Goods order (including placement of Goods order as a Guest), etc.).

3.2. The Website does not collect automatically any Personal information of yours. Please note that the Website automatically collects the Anonymous data about you specified below:

3.2.1. the data that are contained in the Cookies files. More detailed information regarding a policy of use of Cookies is available for you reference in the Cookies policy part of the Privacy policy;

3.2.2. the Website may also collect information that is usually collected by the system administrators, also information about logs. Information contained in logs inter alia may store IP address, a log in platform and Internet browser, provider of Internet services and address of the website from which the Website was accessed by the Visitor and (or) Customer who is not logged in to his/her account.

3.2.3. Some sub-categories of the Website and other measures of communication with the Customer may encompass so called “Web Beacons”. Web Beacons are used for evaluation of the Seller’s advertising efficiency. These data will not be associated with your Personal information. These data will be archived and used for statistical analysis and assessment of movement of the Visitors and (or) Customers of the global Website. Web Beacons allow collection of various information, including IP address, URL website number, Website load time, type of browser and information contained in the cookie.

4. Collection and use

4.1. Every time the Visitor and (or) Customer, who is not logged in to his/her account, visits the Website, the Seller‘s servers temporarily save information about the logging device, i.e. the Anonymous information listed in clause 3.2 of the Privacy policy. In the context of this procedure, regardless of actions of the Visitor and (or) Customer who is not logged in to his/her Account, the Anonymous information specified is automatically collected and stored until it is deleted automatically and / or manually. This Anonymous information is collected and processed in order the Visitor and (or) Customer, who is not logged in to his/her Account, could use the Website (to connect), in order to guarantee permanent system security and stability, in order to enable technical administration of the Website infrastructure, also in order to optimize operation of the Website and activity of the Seller herewith and for the purposes of internal statistics. Furthermore, IP address can be analysed and used in cases of infringement of the Rules, attacks against the Website infrastructure, for statistical purposes and in other cases when this Privacy policy or applicable legal acts provide so.

4.2. When the Customer logs in to his/her Account, the Seller collects and stores Personal information that identifies the Customer. In such case the following Personal information about the Customer can be collected and stored:

4.2.1. first and last name, email address, post address, phone number, other contact information and any other information available in your Account;

4.2.2. when the Customer wishes to receive Invoice for Goods purchased / acquired, for the purposes of invoicing and acceptance of Invoices – financial information provided by the Customer at the time of acquisition of Goods;

4.2.3. information about your actions that are performed in the Website by you as the Customer (including history of Goods purchase);

4.2.4. for the purposes of administration of the Website the Seller may also collect information about the device using which you log in to the Website (e.g. personal computer, laptop, mobile phone, etc.);

4.2.5. other information associated with your actions in the Website when you acquire Goods, use the Website, including identification number of device, information about log in, page-view statistics and data about standard log in information;

4.2.6. additional information from you or about you that is not described separately in this document (e.g. information associated with your appeal to the Seller);

4.2.7. other information provided by you in the Website, including your choice to receive promotional offers of the Seller or not, as described in section Advertising and online surveys of the Privacy policy.

4.3. The main purpose of collection of your Personal information: to ensure smooth operations encompassing actions in the Website and acquisition of Goods, to ensure safe, effective and tailored operations. You agree and confirm that the Seller shall be entitled to use your Private information, including the one that is specified in clause 4.2 of the Privacy policy, for the following purposes:

4.3.1. recognition of the Customers in the Website and administration of the Customers‘ Account;

4.3.2. execution of Goods orders, transfer and delivery of Goods to the Customer and assurance of access to the services and information offered in the Website;

4.3.3. improvement of the Website in order to tailor it to your needs, i.e. by adapting, assessing and improving I) execution of Goods purchase and sale transactions using the measures of the Website; II) services of the Website; III) a content of the Website; and (or) IV) advertising;

4.3.4. handling of consumer complaints, if any;

4.3.5. verification of data sent from the Website;

4.3.6. execution of demographic research of the Customers;

4.3.7. prevention, detection and analysis of possibly prohibited or illegal actions in the Website;

4.3.8. notification of the Customers on the Seller‘s Goods;

4.3.9. execution of direct marketing when a separate consent of the Customer is available;

4.3.10. provision of other services of the Website and Customer assistance, for other purposes specified in this Privacy policy as well as for other purposes specified in a particular case when information is collected.

4.4. Provision of Personal information specified in clause 4.2 of the Privacy policy and agreement about its processing represent a voluntary act that is necessary in order to ensure proper and comprehensive use of the Website by the Customer and in order the Seller could properly execute the orders placed by the Customer.

4.5. The Seller stores actual data about Goods orders of the Customer. However, in order to ensure security of the Customer‘s data, the Seller cannot directly access them. As Customers you can get all information about Goods orders placed for the Seller after having logged to your Account. Using tools that are available in the Account you may review your Goods orders and change your contact details. In compliance with the requirements and procedures specified in the Rules, you must keep safe your data of access to the Account and not disclose them to the third parties.

4.6. Information collected by the Seller when the Customer registers and (or) participates in surveys is also used to improve the Website services, to meet the Customers‘ needs and requests, including use of information for the purposes of direct marketing, in so far as this concerns the Website services provided to the Customer.

4.7. In accordance with the Privacy policy, the Seller shall also be entitled to use the Personal information of the Customer for its internal purposes, including communication with the Customer via email in order to notify the Customer on updates of Goods and the Website and to provide the Customer with information associated with e-commerce transactions entered into by the Customer in the Website, etc.

5. Advertising and online surveys

5.1. The Seller does not grant access for the third parties to the Customer‘s Personal information and does not transfer any information about the Customer to the third parties without a separate consent of the Customer.

5.2. The Seller will send the Seller‘s commercial / advertising information (newsletters, etc.) to the contact email address and (or) phone number pf the Customer only upon receipt of a separate consent of the Customer provided by the latter during filling out of registration forms or otherwise (e.g. via so called check-box window). With your consent available at the Seller‘s side we will send such information (e.g. newsletters) to you as SMS message and (or) to your email address. Your consent, allowing us to send such information to you, is voluntary and is unnecessary for execution of Goods orders and can be revoked at any time. If you will not provide us with a separate consent, but later will change your mind about receiving from the Seller the commercial / advertising information specified in this clause, you can submit us an application at any time to email address: info@comflowgroup.com or using other setting of the Website (if any are applied).

5.3. In any case, you cannot refuse to receive administrative information from the Seller associated with acquisition of Goods, services provided by the Seller or the Website (including the Rules), except when the account is deleted. Furthermore, you cannot refuse from notifications sent by the Seller containing legal information that is associated with Goods acquisition and (or) use of the Website.

5.4. In order to collect information about things that are considered preferable by the Visitors and (or) Customers using the Website as well by the Customers when they acquire Goods, the Seller can conduct surveys of the Visitors and (or) Customers. These surveys are optional. If you will decide to take part in such surveys, your answers will remain anonymous, unless stated otherwise during a specific survey. We can also organize surveys in accordance with specific requirements. During such surveys the Customers can be requested to provide a contact and demographic information, including first name, last name, email address and post address. In any case, the Seller will not provide such information to any third parties, unless provided otherwise in specific case.

6. Disclosure of information

6.1. The Seller shall be entitled to disclose your Personal information where required by applicable legal acts and when implementing legal and reasonable policies and rules of the Seller, i.e. policies and rules that comply with the requirements of legal acts, e.g. when responding to complaints received or other complaints when the rights of the third parties or legitimate interests are violated or in order to protect other persons, their legitimate interests or property.

6.2. A separate explicit consent of the Customer, as stipulated in clause 4.3.9 of the Privacy policy, provides a lawful basis for the Seller to disclose Personal information of the Customer for the purposes of Direct marketing.

6.3. You agree and confirm that the Seller can provide your Personal information:

6.3.1. to the Seller‘s partners – the third parties invoked by the Seller as service providers during execution of Goods order and provision of other services to in order to receive services of the Third parties (to partners providing services Goods collection, payments collection, other services ordered by the Customer as well as to the Seller‘s partners providing services of support and maintenance of the Website, other services that help the Seller develop its activity or perform other operations in the Website);

6.3.2. to other third parties when you submit an appropriate request to provide your Personal information (or to the third parties about which you are notified explicitly otherwise and when the Seller agrees with you regarding provision of information using a specific service);

6.3.3. to law enforcement authorities in accordance with the legal acts of the British Isles and if it is necessary to prevent criminal offences or when it is necessary to investigate them;

6.3.4. to structural subdivisions of the Seller or its connected undertakings;

6.3.5. to other business entities if a merger of the Seller with another legal entity would occur, if the Seller would acquire another legal entity or if another legal entity would acquire the Seller, also in cases of transfer of the Website or property/assets associated with the Website.

6.4. In cases referred to in clause 6.3 of this Privacy policy the Seller will transfer a minimum amount of your Personal information. The Seller will not transfer, lease your Personal information to the third parties and will not further distribute the same without your consent (prior or separate) expressed explicitly, except in so far as this is essential for implementation of provisions established in the Privacy policy or when the Seller will be legally bound to do so.

6.5. Data and information indicated by the Customer are known only to the Customer, Seller and the Seller‘s partners who must maintain confidentiality of these data. The Seller shall be held responsible for the actions of its partners. The Seller guarantees that the Seller will not disclose to other parties the data and information indicated by the Customer until the Customer will publish his/her comments or other content in the Website that will be visible to other persons who use the Website, together with the data that will be provided in such case, unless entities having the right to receive such information from the Seller would ask or request to disclose the Customer‘s data and information in accordance with the applicable legal acts.

7. The rights and duties of the Customers relating to processing of their Personal information in the Website

7.1. The parties are requested to provide Personal information during their self-registration in the system as a Customer, i.e. during opening (creation) of Account in the Website.

7.2. Registered Customers can log in to their Account and autonomously manage Personal information provided in their registration form, can change the data provided therein, update or remove these data. If, in your opinion, this decision is inadequate, you shall have the right to contact the Seller, you shall be entitled to contact the Seller in the way referred to in clause 11.3 of the Privacy policy. The Seller will not change manually your Personal information. Therefore, you understand and undertake to update your Personal information on immediate basis in case of its change or when it is inaccurate.

7.3. Your password serves as a key to your Account. You should use unique digits, letter and specific signs to create your password and should not disclose the password of your Account to other persons. You can change and update your details at any time after having logged in to your Account. If you forgot your login password or encounter other problems during login to your Account, please contact us by email: info@comflowgroup.com or by other contacts specified in the Rules.

7.4. If you will disclose your password or any other information of your Account to other persons, you will be responsible for all and any actions performed using your Account, unless proved to the contrary. If you will lose your password, you will not be able to control the actions performed with your Personal information and other persons may assume liabilities on your behalf, but you will have to take responsibility for such liabilities of other persons. Therefore, if you suspect that any other person can use your password, you should immediately notify the Seller thereof by contacts specified in clause 7.3 of the Privacy policy. You should use unique digits, letter and specific signs to create your password and should not disclose the password of your Account to other persons. You can change and update your details at any time after having logged in to your Account. If you forgot your login password or encounter other problems during login to your Account, please contact us by email: info@comflowgroup.com or by other contacts specified in the Rules.

7.5. Please note that when you connect to the Website from a generally used computer or computer in Internet café, other person who will use the same computer after you may also see a particular information about you. If you share computer with other persons, you should always log out from your Account having finished using the computer. You must log out even when you get away from your computer only for a short moment. Thus you will prevent other persons from seeing, use or change Customer information or data…

7.6. If you do not wish the Seller to process your Personal information, you can notify the Seller on such refusal at any time by submitting your request. Such request can be submitted in the way referred to in clause 11.3 of the Privacy policy. Upon receipt of such refusal you will be deprived of your Customer status and will be unable to use the Website as Customer.

7.7. The Seller shall have the right to retain your Personal information until your Account will be withdrawn in accordance with the provisions of the Privacy policy and (or) the Rules. Your Account is withdrawn and your Personal information is deleted in accordance with the provisions of the Private policy and the Rules. After withdrawal of your Account you will lose access to your data in the Website, unless otherwise stipulated by the Privacy policy or the Rules.

7.8. In order to ensure implementation of Personal information gathering objectives provided in this Privacy policy, your Personal information can be retained for a period of no more than 2 (two) years after your last log in to the Account. Nevertheless, when there are justifiable grounds for doing so, the Seller reserves the right to determine a respectively shorter or longer period for retention of Personal information.

7.9. Not limited to the above provisions, the Seller shall in all cases retain Personal information about the Customers who were removed from the system due to infringement of the applicable legal acts or the Rules.

8. Data protection

8.1. The Seller in particular endeavours to ensure security of the data of its Visitors and (or) Customers. In order to ensure security of information and data transferred, the Seller implements security and organizational measures that match a threat of security of service provision. The Seller uses reasonable physical, electronic and procedural means and methods in order to protect information (including Anonymous information) against loss, theft or any unauthorized use, disclosure or change.

8.2. All logins associated with execution of the Customer‘s payments, in accordance with customer’s choice will be conducted by establishing a secure connection to the website used.

8.3. Please note that regardless of the Seller’s use of the reasoned measures set out above, the Seller cannot guarantee and does not guarantee security of your Personal information because it is provided or collected online. Furthermore, the measures used by the Seller may not be sufficient if you will fail observe security rules. First of all, the Customers must not disclose their login data to the third parties. Please note that you will be requested by the Website measures to provide such data as email address and password only at the time of login to the Account. In order to prevent unauthorized use of your Account, you should log out from your Account after having finished your work in the Account and (or) the Website.

8.4. Your actions can also reduce the risk of unauthorized use of Personal information. Therefore, you should be careful and choose clever protective measures, for example, you should choose a complex password, use the latest antivirus software, etc.

8.5. You shall be entitled to request the Seller to provide you with all information about your data processed by the Seller. The Customers shall also have the right to request amendment, update or removal of these data and correction of mistakes. The Customers can also object to processing of Personal information for the purposes of direct marketing. If you wish to exercise this right, please contact us by email: info@comflowgroup.com.

9. Cookies Policy

9.1. Cookies are used in the Website. The Seller uses Cookies for the following purposes:

9.1.1. for proper functioning of the Website and improvement of your browsing (e.g. maintenance of your session after login, to remember your settings, etc.);

9.1.2. for advertising and direct marketing;

9.1.3. gathering of statistical data of the Website and improvement of the Website;

9.1.4. The Website uses “Google Analytics“ software created and provided by “Google Inc.“ (hereinafter referred to as “Google“). The software is designed for analysis of Internet websites. “Google Analytics“ uses Cookies that help analyse how the Customers and Visitors use the Website. Information generated by Cookies on how the Customers and Visitors use the Website (together with IP address) is transferred to Google server in USA where it is stored. Google will use this information to analyse how the Customers and Visitors use the Website, for preparation of statements about popularity of the Website for its operator and to provide other services associated with the Website and its use. Google can forward this information to the third parties if required by applicable legal acts or if these third parties process information on behalf of Google. Google will not associate your IP address with any other data that are in possession of Google. You can make certain settings in your browser software to prevent Google from installing Cookies. However, please note that this may prevent you from using all functions of the Website. By using the Website you consent and confirm that all data relating to your activity in the Website can be used by Google for the above-mentioned purposes and in the above-mentioned ways.

9.2. All Cookies used in the Website can be temporary or permanent:

9.2.1. temporary Cookies are valid and are not removed as long as you brows in your browser;

9.2.2. permanent Cookies are not removed after closing of browser and information stored in such Cookies facilitate later access to your account (password, email address). Such Cookies speed up and facilitate use of the Website.

9.3. By using the Website you confirm that you consent and allow the Seller to store Cookies in your end device (computer, phone set, etc.).

9.4. With help of your browser software you can block use of Cookies at any time and remove permanent Cookies. For more information on how to manage Cookies in your browser, see the “Help” tab on the Internet browser’s menu.

9.5. Blocking or restricting cookies may affect some of the Web site’s functions.

9.6. The Website uses the following cookies:

 
9.7. Please note that Cookies can be also used by the Seller‘s partners or other third parties not controlled by the Seller. The Seller cannot be and is not liable for actions of such persons. If you suspect that the Seller, partners or other third parties not controlled by the Seller use Cookies without your consent, you should contact the specific partner of the Seller or another third party.

10. Third parties

10.1. This Privacy policy specifies use and disclosure of information collected by us from you through the Website only, unless otherwise specified in the Privacy policy. If you disclose your Personal information through the Website or other websites to other persons, whether they are Clients or third parties, then other rules may be applied for use and disclosure of relevant information.

10.2. The Website may contain links to other websites. The Seller does not control a content of such website and shall not be held responsible for their content. Such websites may have their own privacy policies. The customers are recommended to make familiar themselves with these policies. The Seller does not control privacy policies and (or) other rules applied in your respect by the third parties. Therefore, you, at your own risk and at your own discretion, are responsible and undertake to comply with them in cases where they are applicable in your respect. The Seller shall not be held responsible for privacy policy of other websites or any other content when the Website contains a link other websites or when other websites contain a link to the Website. Please note that when you press on a link, logo or other Website element or when you use the services available in the Website, including online communication, you can get out of the Website.

10.3. The Seller does not collect any information about the Customers from the third parties, except in cases provided in the Privacy policy or the Rules, also when regulatory requirements are not met, the Rules are not observed or the rights of the third parties are infringed.

11. The final provisions and settlement of disputes

11.1. Applicable rights and the rules applicable for the issues of dispute resolution are specified in the procedure of use of the Website.

11.2. The Seller reserves the right to adjust from time to time this Privacy Policy or any part of it and any related