GANT - Online Shopping for Women, Men and Children

PRIVACY POLICY

Dear Users,

Please be advised that this page describes the general rules for administering the website www.pl.gant.com , belonging to Gant Polska Sp. z o.o. with its registered office in Warsaw (00-120 Warsaw), ul. Złota 59, NIP: 7010341947, REGON [National Business Registry Number]: 146127374, registered in the Register of Entrepreneurs kept by the District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division of the National Court Register, KRS number 0000419724, with the share capital of 13,038,100.00 PLN, with reference to personal data of users who visit it.

These rules apply in all cases of visiting our pages, without registering or filling in or entering data in web forms.

By visiting the pages of this site, you accept the conditions listed below. If you do not accept the rules, please do not visit or use the services offered through our website.

GENERAL PRINCIPLES

1. This document Privacy Policy and Cookies contains information about:

a. ways and principles of processing and protection of personal data of users of the website http://www.pl.gant.com ("Website") administered by Gant Polska Sp. z o.o. with its registered office in Warsaw (00-120 Warsaw), ul. Złota 59, NIP: 5272725346, REGON [National Business Registry Number]: 360192638, registered in the Register of Entrepreneurs kept by the District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division of the National Court Register, KRS number 0000419724, with share capital 8.325.000,00 PLN; ("Gant Polska"), e-mail: gdpr.east-europe@erenretail.com[DN2] , ("Privacy Policy");

b. cookies.

2. Privacy Policy and Cookies indicates the rules of conduct in all matters relating to the processing and protection of personal data in the sense given by the provisions on the protection of personal data, in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on protection of individuals with regard to the processing of personal data and on the free transfer of such data and the repeal of Directive 95/46/EC (Journal of Laws UE L 119, p. 1) ("GDPR") and the Act of May 10th 2018 on the Protection of Personal Data ("Act on the Protection of Personal Data").

These rules are also in line with the Act on Electronic Services of July 18, 2002, as well as the Telecommunications Act of July 16, 2004.

3. PLEASE NOTE! Please be advised that the Site may contain external links that allow users to directly access other websites. Gant Poland has no influence on the privacy policy and the use of cookies on other websites and is not responsible for them.

We suggest that before using the resources offered by other websites, you should read the privacy policy document and the use of cookies, if available, or if they are not available, contact the website owners for information on this subject.

Gant Poland declares that the content of the Website does not violate any rights of third parties or applicable law, in particular it is free from content containing information that could cause or threaten the privacy or safety of any person, information that promotes illegal activities or behaviour that are offensive, threatening, indecent, defamatory or slanderous, incite to racism, prejudices based on ethnic origin, culture, or for religious reasons that promote or facilitate criminal activity, violate the rights of third parties, including intellectual property rights or constitute another form of violation of rights protected by law.

4. Each visitor to the Website automatically becomes its User ("User"). The User using the Website or providing personal data accepts the principles described in this Privacy Policy and Cookies.

In the event of disagreement with the content of the Privacy Policy and Cookies, the User should not use the Website and provide personal data to Gant Poland.

5. In certain cases, specific information regarding privacy protection will be provided additionally or the User will be asked to give specific, voluntary consent directly in the place and at the moment in which he gives his personal details to Gant Poland or interacts with Gant Poland.

PERSONAL DATA ADMINISTRATOR

The data controller of personal data is Gant Polska Sp. z o.o. with its registered office in Warsaw (00-120 Warsaw), ul. Złota 59, NIP: 5272725346, REGON [National Business Registry Number]: 360192638, registered in the Register of Entrepreneurs kept by the District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division of the National Court Register, KRS number 0000530331, with the share capital of 8.325.000,00PLN ("Administrator").

In order to exercise your rights and obtain further information regarding the processing of data as well as information whether personal data is processed and to what extent, you may contact the Administrator by writing to gdpr.east-europe@erenretail.com

The administrator appointed the Data Protection Inspector available at gdpr.east-europe@erenretail.com or by correspondence at Gant Polska Sp. z o.o. ul. Złota 59, 00-120 Warsaw.

PERSONAL DETAILS

Personal data means information about an identified or identifiable natural person (the "data subject") ("personal data"). An identifiable natural person is a person who can be directly or indirectly identified, in particular on the basis of an identifier such as name, identification number, location data, internet identifier or one or more specific factors determining physical, physiological, genetic, psychological, economic, cultural or social identity of a natural person.

Personal data may also include unique numeric identifiers, such as the User's computer's IP address or the User's mobile device's MAC address, as well as Cookies.

RULES FOR COLLECTING PERSONAL DATA

Personal data about the User may be collected by Gant Poland from a number of sources, including:

a. provided directly by the User Gant Poland collects data on how the User uses our services and products, e.g. information about the types of content that he or she watches or deals with, and the frequency and duration of his/her activities. Gant Polska also collects personal data provided during registration in the Newsletter, registration to purchase our products and completing surveys.

b. personal data that Gant Poland collects automatically Gant Poland also receives and stores certain types of personal information each time the User contacts Gant Poland online. Personal data is also collected when searching, shopping, participating in competitions and surveys, and communicating with our customer service teams. c. personal data that Gant Poland collects from other sources. We collect personal data from other sources, e.g. from our trusted external partners and external platforms, in which Gant Poland has accounts (e.g. Facebook).

The Website is designed and intended for adult Users.

Gant Poland does not collect or consciously collect personal information about children under the age of 18. If it is discovered that Gant Poland has accidentally collected personal information from children under the age of 18, it will be deleted immediately.

STORAGE OF PERSONAL DATA

Personal data collected by Gant Poland is stored in the European Economic Area ("EEA").

Gant Poland hereby informs that this data can also be sent to a country outside this area and processed there.

In the case of such operations, for countries for which the European Commission has not found an adequate level of data protection, Gant Poland applies standard contractual clauses as a means to secure compliance of operations with applicable law and data entrustment agreements that meet the requirements of the GDPR.

The content of the Standard Contractual Clauses can be found by clicking on the link: https://eur-lex.europa.eu/legal-content/PL/TXT/?uri=CELEX:32010D0087

In the case of transfer of data from Europe to the USA, some entities located there may additionally provide an adequate level of data protection within the so-called EU-US Privacy Shield (Privacy Shield).

Some providers have a Privacy Shield certificate, which you can check by clicking the link below: https://www.privacyshield.gov/welcome

User's personal data is stored by Gant for the time strictly necessary to achieve the relevant purpose (unless this Privacy Policy indicates in detail the duration of storage of personal data).

Then Gant will store properly stored and protected personal data for such a period of time for which liability for processing may arise, in accordance with the regulations in force at any time.

After the limitation period of possible actions, depending on each case, Gant will proceed to delete the User's personal data. Gant ensures that every person acting under his authority and having access to the User's personal data processes them only on Gant's instructions, unless other requirements result from the law of the Union or the law of a Member State.

Gant reserves that it may transfer personal data within the capital group to which Gant belongs on the basis of Gant's legitimate interest for the purposes of internal management, ensuring compliance with legal obligations, preventing fraud and / or to secure tools, improving Gant's products and services or after receiving the User's consent for such action.

Depending on the purposes for which they were collected, and only when necessary, some of the User's personal data may be disclosed to entities within the capital group to which Gant belongs, also located outside of Poland, on the basis of Gant's legitimate interest for the purposes of internal management, where possible in a pseudonymous manner and where necessary to provide the User with the service he requested.

The catalog of recipients of personal data processed by Gant always results primarily from the scope of services used by the User.

The catalog of data recipients also results from the User's consent or legal provisions and is clarified as a result of actions taken by him in the E-Store (see Regulations of the E-Store).

TRUSTED PARTNERS

Limited processing of personal data may involve trusted Gant partners ("Trusted Partners"), in particular those who technically help to run the Website or E-Store efficiently, providers of hosting services or ICT services, carriers or intermediaries carrying out shipments of orders, entities handling payments electronic or payment by card in the E-Shop, companies that service software, support Gant in marketing campaigns, as well as providers of legal, accounting and consulting services.

Gant has Standard Contractual Clauses approved by the Commission with Trusted Partners who are based outside the EEA.

Gant works with external courier companies to deliver.

These courier companies receive the following data to carry out a specific order:

• User's name and surname

• Delivery address

• possibly a postal number (if the order is to be delivered to a parcel locker)

• possibly an email address (if the courier company wants to inform the user by e-mail about the planned delivery date)

In order to provide services to Users, Gant also cooperates with technical service providers.

If these entities process Users' data outside of EOA, Gant ensures that the respective service provider has contractually or otherwise guaranteed an equivalent level of data protection.

In the case of obligations imposed by offices or courts or for the purpose of legal or criminal prosecution, Gant will provide Users' data if necessary to criminal prosecution authorities or other third parties.

Gant Poland ensures that every person acting under Gant Poland’s authority and having access to the User’s personal data should processed it only on the Gant Poland order, unless other requirements arise under EU or law of the member State. Gant Poland reserves the right to provide personal data within a capital group to which Gant Poland belongs based on Gant Poland's legitimate interest for internal management purposes, compliance with legal obligations, fraud prevention and/or to secure tools, improve Gant Poland products and services, or after receiving the User's consent for such action. Depending on the purpose for which the data was collected, and only when necessary, some of User’s personal data may be made available to entities within the capital group to which Gant Poland belongs, also located outside of Poland, on the basis of Gant Poland's legitimate interest for the purposes of internal management, where possible in a pseudonymous manner and where necessary to provide the User with the service for which he requested. The catalogue of recipients of personal data processed by Gant Poland always results primarily from the scope of services used by the User. The catalogue of recipients of the data also results from the consent of the User, or from the provisions of law, and is clarified as a result of actions taken by him in the E-Store (see the E-Store Terms and Conditions). Gant Poland's trusted partners ("Trusted Partners ") may participate in the processing of personal data, in particular those who technically help efficiently run the Website or E-Store, hosting service providers or ICT services, carriers or intermediaries performing orders shipments, service providers electronic payments or card payments in the E-Store, companies that service the software, support Gant Poland in marketing campaigns, as well as the providers of legal, accounting and consulting services. With Trusted Partners who are established outside of the EEA, Gant Poland has signed the Standard Contract Clauses approved by the Commission.

SCOPE OF PERSONAL DATA, PURPOSES AND LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

The purpose and scope of the data processed by Gant personal data results each time from a specific legal basis specified by the GDPR. In some cases, it is the User's consent, in others legal provisions, sometimes the need to perform the contract or the legitimate legal interest of the Administrator. Detailed information is presented below.

The most common purposes of processing Users' personal data by Gant are in particular:

• conclusion and implementation of the Agreement for the provision of the Customer Account Service

• news

• taking action at the request of a future client before concluding it; conclusion and implementation of the Sales Agreement or taking action at the request of a future Customer before its conclusion

• receiving and processing complaints;

• conducting the competition, in particular selecting the winners;

• implementation of awards;

• presenting advertisements, offers or promotions (discounts) regarding Gant products or services

• providing the Newsletter service

• assessment and analysis of User activity and information, including as part of automated processing of personal data (profiling), to present general advertisements, offers or promotions (discounts) regarding Gant products or services in a manner tailored to the interests of a given User (without, however, significantly affecting his decisions), in particular to implement the contract for the provision of the Newsletter,

• market and statistical analyzes;

• pursuing claims and defending against claims, including third parties;

• fulfilling legal obligations arising from regulations, e.g. tax and accounting, especially in the case of paid contracts or conducting correspondence with the User, including responding to Users' messages.

Gant Poland processes personal data only for specific and limited purposes, i.e.

a. CUSTOMER ACCOUNT SERVICE

TYPES OF PROCESSED DATA: contact details, such as name, address, country, e-mail address and phone number, User ID, password, age, account settings, and in the case of purchasing, also information on payments and payment history, information on the subject of orders, deliveries, order history, encrypted credit card data (without CVV or CVC security code), personal data related to cookies, in particular click history and history of navigation and browsing, and if the user asks for a VAT invoice, NIP and REGON number. The registered User Account may be closed at any time by contacting us via the Customer Service Office info@pl.gant.com.

PURPOSE: Gant Poland processes the above personal data in order to provide the Customer Account service (free electronic service referred to in Article 10 b of the E-Store Terms and Conditions) and enable the User to use certain Website functionalities and provide him/her with access to various functions, products and services that are available to him/her as a registered User, e.g. to be informed individually about changes to the E-Store Regulations or Privacy Policy and Cookies or about promotions, as well as saving products in the basket. In the case of a purchase, Gant Poland processes the above-mentioned personal data in order to fulfil orders and returns and to send the User notifications of the delivery status or in case of any problems with the delivery of products, as well as to manage payments or process complaints.

DATA STORAGE PERIOD: Gant Poland will store the User’s personal data during the term of the contract for the provision of the Customer Account service in which the account will be active. If the data processing by Gant Poland is carried out on a different legal basis as indicated in THE LEGAL BASIS below, then the User's personal data will be kept for the whole period of existence of this legal basis. In any case, a longer period of storage of personal data is decisive.

GIVING ACCESS TO PERSONAL DATA: Gant Poland provides the personal data of the User to Trusted Partners only to those who are responsible for the correct and uninterrupted operation of the Customer Account. In the event of a purchase by the User, Gant Poland provides the User's personal data to the Trusted Partners, i.e. in particular to courier companies, payment processing companies, debt collection companies, law firms, and the accounting firm only to ensure the implementation of the objectives set out above.

LEGAL BASIS: The processing of personal data takes place on the basis of an agreement with the User to open the Customer Account service or when it is necessary to take action at the request of the User related to the launch of this service (Article 6 paragraph 1 letter b) of the GDPR). At the same time, in the event of a purchase by the User or notification of the complaint, apart from the legal basis indicated above, Gant Poland also has the right and obligation to process the data for not less than the period required by law, including in particular tax laws and the Accounting Act (Article 6 paragraph 1 letter c) of the GDPR). In addition, Gant Poland has the right to process the User’s personal data when it is necessary for purposes arising from legitimate interests pursued by the Administrator, and so in the event of determining, investigating or defending against User's claims (Article 6 paragraph 1 letter f) of the GDPR). If the User wants to use the option of receiving direct marketing information, organizing competitions, promotions, surveys, loyalty program, the personal data processing is based on the User's consent (Article 6 paragraph 1 point a) of the GDPR) .

b. ONLINE PURCHASES MADE BY THE USER

TYPES OF PROCESSED DATA: contact details such as name, address, email address and phone number, payment information and payment history, age, gender, country, encrypted credit card information (without CVV or CVC security code), and in case the User will ask to issue a VAT invoice, also NIP and REGON If the User additionally uses the Customer Account service, Gant Poland will also process information on order history, delivery, User ID, password and account settings as well as personal data related to cookies, in particular click history and navigation and browsing history.

PURPOSE: Gant processes the above personal data in order to process orders and returns, to manage clothes availability questions, product reservations through the Website or to provide services related to the personal tailoring function, depending on the availability of these services at a given moment and to send the User notifications about the status of delivery or in case of any problems with the delivery of products, as well as for payment management, for invoicing purposes and to issue receipts and invoices for purchases made via the Website or complaint processing.

DATA STORAGE PERIOD: Gant Poland will store the User’s personal data for as long as it is necessary for the User to complete the purchase agreement. If the data processing by Gant Poland is carried out on a different legal basis as indicated in THE LEGAL BASIS below, then the User's personal data will be kept for the whole period of existence of this legal basis. In any case, a longer period of storage of personal data is decisive.

GIVING ACCESS TO PERSONAL DATA: Gant Poland provides personal data of the User to the Trusted Partners, i.e. in particular to courier companies, payment processing companies, debt collection companies, law firms, and the accounting firm only to ensure the implementation of the objectives set out above.

LEGAL BASIS: The processing of personal data is necessary to perform the online shopping service, or to take action at the User's request prior to the conclusion of the contract (Article 6 paragraph 1 letter b) of the GDPR). At the same time, Gant Poland also has the right and obligation to process data for not less than the period required by law, including in particular the provisions of tax laws and the Accounting Act (Article 6 paragraph 1 letter c). In addition, Gant Poland has the right to process the User’s personal data when it is necessary for purposes arising from legitimate interests pursued by the Administrator, and so in the event of determining, investigating or defending against User's claims (Article 6 paragraph 1 letter f) of the GDPR).

c. PROCESSING USERS’ REQUESTS

TYPES OF PROCESSED DATA: contact details such as name, address, email address and phone number, payment information and payment history, age, gender, country, encrypted credit card information (without CVV or CVC security code), and in case the User will ask to issue a VAT invoice, also NIP and REGON, correspondence with the User regarding his or her requests and expectations. If the User additionally uses the Customer Account service, Gant Poland will also process information on order history, delivery, User ID, password and account settings as well as personal data related to cookies, in particular click history and navigation and browsing history.

PURPOSE: Gant Poland processes the above personal data in order to answer User's questions, process User's complaints about products and technical questions submitted by e-mail or telephone, as well as in case when it is necessary to contact the User in connection with his or her order, delivery, product return or product shipment. Gant Poland processes the above data in order to better understand the needs and expectations of the Users and thus improve their services, products and brands, as well as for statistical purposes(art.6 par.1 lit.f) GDPR).

DATA STORAGE PERIOD: Gant Poland will process the above personal data until the User's application is definitively terminated. If Gant Poland will process data on a different legal basis as indicated in THE LEGAL BASIS below, then User’s personal data will be kept for the whole period of existence of this legal basis. In any case, a longer period of storage of personal data is decisive

LEGAL BASIS: The processing of User’s personal data by Gant Poland is necessary for purposes arising from legitimate interests pursued by the Administrator in particular to establish, investigate or defend claims, conduct correspondence with Users, also via contact forms (including replying to users' messages), market and statistical analyses (Article 6 (1) (f) of the GDPR). In the event of answering Users' inquiries, Gant's processing of User's personal data takes place on the basis of the User's consent (art.6 par.1 lit.a) RODO), and in cases related to user reports resulting from the implementation of the on-line sales contract, processing it may be necessary to perform the contract (art.6 par.1 lit.b) GDPR) and subsequently to fulfill the legal obligation incumbent on the administrator (art.6 par.1 lit.c) GDPR).

d. NEWSLETTER SERVICE TYPES OF PROCESSED DATA: contact details, such as name, address, gender, country, e-mail address and phone number, User ID, password, age, account settings, personal data related to cookies, in particular click history and navigation and browsing history.

PURPOSE: Gant Poland processes the above personal data for the purpose of completing the Newsletter service (free electronic service referred to in Article 10 a of the E-Store Terms and Conditions) and allowing receiving information about new services or products offered by Gant Poland via e-mail. For more information, please go to the section on Profiling.

DATA STORAGE PERIOD: Gant Poland will store the User’s personal data during the term of the contract for the provision of the Newsletter service. If the data processing by Gant Poland is carried out on a different legal basis as indicated in THE LEGAL BASIS below, then the User's personal data will be kept for the whole period of existence of this legal basis. In any case, a longer period of storage of personal data is decisive. If the user does not want to receive individual product proposals by email, he can opt out of this service in any form at any time, e.g. by email, without incurring costs except for the costs of providing information according to basic tariffs (e.g. costs of Internet connection, postage fees ). Of course, a resignation link is available in every email. If the User does not want to receive individual product suggestions from us using the push service, he can deactivate this function in the application's settings at any time. In most of our applications, a specific function is available in the "Settings" section of the "Notifications" or "Push Messages" menu.

GIVING ACCESS TO PERSONAL DATA: Gant Poland provides the personal data of the User to Trusted Partners only to those who are responsible for the correct and uninterrupted operation of the Newsletter.

LEGAL BASIS: The processing of personal data takes place on the basis of an agreement with the User to open the Newsletter service or to take action at the request of the User related his/her commencement of this service (Article 6 paragraph 1 letter b) of the GDPR). In addition, Gant Poland has the right to process the User’s personal data when it is necessary for purposes arising from legitimate interests pursued by the Administrator, and so in the event of determining, investigating or defending against User's claims (Article 6 paragraph 1 letter f) of the GDPR).e.

e. SERVICE CONTACT FORM

TYPES OF PROCESSED DATA: contact details, such as name, e-mail address and phone number, age, personal data related to cookies, in particular click history and navigation and browsing history.

PURPOSE: Gant Poland processes the above-mentioned personal data for the purpose of carrying out the Contact Form service (a free electronic service referred to in Article 10c of the E-Store Terms and Conditions) and enabling the User to send messages to Gant Poland via the form available on the E-Store website.

DATA STORAGE PERIOD: Gant Poland will store the User’s personal data during the term of the contract for the provision of the Contact Form. If the data processing by Gant Poland is carried out on a different legal basis as indicated in THE LEGAL BASIS below, then the User's personal data will be kept for the whole period of existence of this legal basis. In any case, a longer period of storage of personal data is decisive.

f. CONTESTS

TYPES OF PROCESSED DATA: contact details, such as name and surname, e-mail address and phone number, age, gender, personal data related to cookies, in particular click history and navigation and browsing history, as well as information provided in the contest.

PURPOSE: Gant Poland processes the above-mentioned personal data based on the User's consent which the User submits at the time of applying for participation in the contest. The User's personal data will be used to allow Gant Poland to contact the Participant in matters relating to the contest, before and after the event, to determine the Participants' identity and verify their age, in order to contact the winners and provide the prize and determine the method of delivery.

DATA STORAGE PERIOD: Gant Poland will store User's personal data for 100 days after the end of the contest.

GIVING ACCESS TO PERSONAL DATA: Personal data will be transferred by Gant Poland to Trusted Partners, that is, to external companies, only for the purpose of providing the services mentioned above and to allow courier companies to deliver prizes.

g. DIRECT MARKETING OF GANT POLSKA PRODUCTS

TYPES OF PROCESSED DATA: if the User uses the Customer Account service, Gant Poland processes contact details, such as name and surname, e-mail address and phone number, age, gender, shopping history, personal data related to cookies, in particular click history and navigation and browsing history. Otherwise, Gant Poland processes contact details such as e-mail address, phone number and zip code, gender (if the User provides such information) and data on products and offers opened on the Website by the User.

PURPOSE: Gant Poland processes the above personal data in order to send the User marketing offers, surveys and invitations - by e-mail, text messages, by phone and traditional mail.

DATA STORAGE PERIOD: Gant Poland will store the User's personal data only during the period of valid consent of the User.

GIVING ACCESS TO PERSONAL DATA: Personal data will be transferred by Gant Poland to Trusted Partners, that is, to external companies, only for the purpose of providing the direct marketing service to Gant Poland. This data will never be disclosed to third parties.

LEGAL BASIS: The processing of personal data takes place at the User's consent (Article 6 paragraph 1 letter a of the GDPR). In addition, Gant has the right to process the User's personal data when it is necessary for the purposes of the legitimate interests pursued by the Administrator, i.e. in the case of establishing, investigating or defending against User's claims (Article 6 paragraph 1 letter f) of the GDPR).The User has the right to withdraw his/her consent to the processing of personal data and to receive direct marketing materials at any time. After the withdrawal of consent, Gant Poland will not send the User any offers related to direct marketing or information sent earlier on the basis of consent to data processing.

h. ONLINE SEARCHING

TYPES OF PROCESSED DATA: depending on the frequency of online interaction of the User with Gant Poland, this data may include the use of the Website, data on the origin of the User, login details, pages visited by the User, videos viewed by the User, advertisements marked by the User, products searched for by the User, the User’s location, the duration of the User's visit, products added by the User to the cart, IP address, information about the browser, a unique identifier given to each visiting User, and the expiration date of such an identifier.

PURPOSE: Gant Poland processes the above-mentioned personal data in order to enable the proper functioning of the Website, proper display of its content, creation and storage of the card; creation and saving of the User's login, personalisation of the interface, such as the choice of language, User's device configuration parameters, as well as to ensure security of the Website and for statistical purposes.

DATA STORAGE PERIOD: Gant Poland will store the User’s personal information only during the valid legal basis for the period indicated below in the “LEGAL BASIS” SECTION.

LEGAL BASIS: The processing of personal data related to cookies takes place due to the legitimate interest of the Administrator (Article 6 paragraph 1 letter f) of the GDPR), i.e. maintaining the security of the Website and enabling it to function. If the purpose is to improve Gant Polska's offers or services, or to send advertisements or deliver tailored content, the processing takes place based on the User's consent (Article 6 (1) (a) of the GDPR).

PRODUCT AVAILABILITY NOTIFICATION

CATEGORIES OF PROCESSED DATA: User's e-mail address, User's telephone number, User's name and surname and data that the User searched for and which are available.

PURPOSE: Gant processes the above personal data at the request of the User in order to send him by electronic or telephone information about the availability of the products indicated by you. The condition for Gant to send such information is to agree to receive commercial information about the products of the online store to the e-mail address provided and to process personal data by Gant or consent on the form provided by Gant.

DATA STORAGE PERIOD: Gant will store the User's personal data only during the period of the valid consent of the User.

LEGAL BASIS: Providing data is voluntary, however, the lack of consent to the processing of personal data makes it impossible to send information about the availability of the product. The processing of personal data takes place on the basis of the User's consent (art.6 par.1 lit.a) GDPR). In addition, Gant has the right to process User's personal data when it is necessary for the purposes of the legitimate interests pursued by the Administrator, i.e. in the case of establishing, investigating or defending against User's claims (Article 6 paragraph 1 letter f) of the GDPR). the right to withdraw your consent to the processing of personal data and receiving direct marketing materials at any time. After withdrawing consent, Gant will not send the User any information about product availability.

j. RETARGETING

Based on cookies, we use technology that allows us to reach advertising messages to users who have previously visited our Site, on other websites they visit, including those belonging to entities cooperating with our partners. The lack of connection between the advertisement displayed to the User and his interests and needs may be burdensome for him. Gant is aware that it is more attractive and practical for the User that the message he receives corresponds to his interests and needs identified as a result of analysis of his previous behavior, based on cookie technology. Therefore, Gant is interested in following advertising content to users using various websites to provide advertising content tailored to his previous Internet activity.

k. IMPLEMENTATION OF GANT LEGAL OBLIGATIONS

CATEGORIES OF PROCESSED DATA: all information about the User required by the provisions of applicable law depending on specific regulations or decisions of the competent authorities, in particular name and surname, contact details (e.g. e-mail address, mobile number), correspondence; information on the time and place of purchase and product defects / complaints, purchase history, other information. In order to fulfill tax and accounting obligations, Gant will in particular process the following Users' personal data: contact details, such as name and surname, address, payment information and payment history, NIP and REGON.

PURPOSE: Gant processes the above personal data to fulfill legal obligations only when necessary. Gant must process personal data to manage the obligations imposed on the company and to combat criminal activities and other abuses, or to fulfill other legal obligations arising from legal provisions, judgments or official decisions. Such requirements may include, inter alia, requirements regarding product liability and product safety, such as communication and providing information to public and consumers about product warnings and product recalls, e.g. in the case of defective products or products posing a health risk or to the extent required by the provisions of individual acts. Gant will also process Users' personal data in order to fulfill legal obligations arising from regulations, e.g. tax and accounting.

DATA STORAGE PERIOD: Data is processed by Gant throughout the lifetime of this legal basis. In the event that Gant will also process Users' personal data in order to fulfill legal obligations arising from regulations, e.g. tax and accounting, the storage period will be 6 years.

SHARE OF PERSONAL DATA: Gant transfers the User's personal data to the competent authorities and institutions. In the event that Gant will also process Users' personal data in order to fulfill legal obligations arising from regulations, e.g. tax and accounting personal data (usually aggregated) may also be transferred to Trusted Partners or shared within the capital group to which Gant belongs.

LEGAL BASIS: Processing is necessary to fulfill the legal obligation incumbent on the controller (Article 6 (1) (c) of the GDPR). In addition, Gant has the right to process the User's personal data when it is necessary for the purposes of the legitimate interests pursued by the Administrator, i.e. in the case of establishing, investigating or defending against the User's claims (Article 6 (1) (f) of the GDPR).

SHARING PERSONAL DATA

Except for the sharing of personal data described above, personal data may also be made available to entities belonging to the same capital group to which Gant Poland belongs and to third parties that support Gant Poland in providing the services offered by the company, that is:

· financial institutions,

· institutions involved in the detection and prevention of fraud,

· technology service providers,

· suppliers and partners in the provision of logistics, transport and delivery services,

· service providers related to customer service,

· suppliers and partners in the provision of services related to marketing and advertising.

In order to maximize the effectiveness of the service provided, some of these service providers are established in countries outside the EEA. In such cases, Users will be informed about the transfer of their data outside the EEA.

PROFILING

When Gant Poland sends or displays personalised information or content (ads, offers, promotions, discounts), in such a situation it can “profile” Users. “Profiling” is any form of automated processing of personal data, which involves the use of personal data to assess certain personal factors of the User, in particular to analyse or forecast aspects of personal preferences, interests, economic situation, behaviour, location, health, credibility or movement.

This means that Gant Poland may collect the User’s personal data as part of the various processes described above.

This allows Gant Poland to better understand the expectations of Users and to adapt to their needs, but without significantly affecting their decisions.

Thanks to the Administrator's use of advanced technologies, the above actions will often be performed by the system in an automated manner, so that the content sent will be the most up-to-date and the User will be able to quickly read them. (ordinary "profiling".

Only for users over 18 years of age, above the analysis of interests and preferences carried out by Gant will also serve to create, grant, implement dedicated and as high as possible adapted to them ads, offers or promotions (discounts) in an automated manner, which may have legal effects on it or similarly significantly affect it , potentially limiting access to them by other Users (not available to Users who are not of legal age and have not consented to such Administrator's actions). These actions, in contrast to the usual "profiling" can significantly affect the User's purchasing choices. The more often a given User uses the services of Gant and purchases his products, the better promotions and surprises can be prepared for him.

In certain circumstances described below, the User has the right to object to the use of his/her data for profiling by withdrawing consent to profiling or changing Cookies settings.

ACCESSING YOUR DATA TO THIRD PARTIES

The functions and services offered and provided by Gant Poland may require Gant Poland to process third-party personal information made available to Gant Poland by Users.

In the case that the User provides personal data of third parties, Gant Poland assumes that the User informed those persons about the purposes and method of their processing.

USER RIGHTS

The User has the right to:

RIGHT TO ACCESS DATA The User has the right to access his/her personal data, which is stored by Gant Poland based on the terms set out in the GDPR. Gant Poand may request a reasonable fee taking into account the administrative costs of providing such information. Evidently unjustified, excessive or repeated applications may remain unanswered. In order to exercise this right, please write to the following e-mail address: gdpr.east-europe@erenretail.com

THE RIGHT TO CORRECT PERSONAL DATA: The User has the right to request the correction of his/her personal data if it is incorrect or out of date, and to complete incomplete data. In order to exercise this right, please write to the following e-mail address: gdpr.east-europe@erenretail.com If the User uses the Customer Account service, he/she can correct or update his/her personal data himself/herself.

THE RIGHT TO DELETE DATA: The User has the right to delete any data processed by Gant Poland. This right will not be fulfilled by Gant Poland, among others in the case of unfinished proceedings in the processing of Users' notifications, an unfinished order which has not yet been sent or has only been partially sent, unpaid debt to Gant Poland, regardless of the payment method, existence of at least suspicion that the User has used Gant Poland services in the last three years in the wrong way to make any purchases, because then Gant Poland will store the User’s personal information about transactions for accounting and tax purposes. In order to exercise this right, please write to the following e-mail address: gdpr.east-europe@erenretail.com .

THE RIGHT NOT TO CONSENT TO THE PROCESSING OF DATA BASED ON THE LEGITIMATE INTEREST OF GANT POLAND: The User has the right not to consent to the processing of his/her data based on the legitimate interest of Gant Poland: In such a situation, Gant Poland will cease the processing of his/her personal data, unless it can demonstrate the legitimate justification of the process that will take precedence over the interests of the User or due to legal claims. In order to exercise this right, please write to the following e-mail address: gdpr.east-europe@erenretail.com

THE RIGHT TO DATA TRANSFER : In the event that Gant Poland processes User's personal data in an automated manner, based on his/her consent or contract, the User has the right to obtain a copy of their data in a structured, commonly used and readable format. This copy may be sent to the User or to another entity. This applies only to personal information that has been provided to Gant Poland. In order to exercise this right, please write to the following e-mail address: gdpr.east-europe@erenretail.com

THE RIGHT TO LIMIT PROCESSING: The User has the right to request that Gant Poland limits the processing of his/her data. This right means that Gant Poland's processing of User's data will be limited to storage and will not be used or processed in any other ways. It applies to limited cases defined in the GDPR, i.e.

(i) the User questions the accuracy of personal data for a period allowing Gant Poland to check the correctness of such data,

(ii) the processing is illegal and the User objects to the deletion of personal data, requesting the limiting of its use, (iii) Gant Poland no longer needs personal data for processing, but it is necessary for the User to establish, investigate or defend claims,

(iv) the User has objected to the processing based on Gant Poland's legitimate interest - until it is established whether the legitimate grounds on Gant Poland's part override the grounds for the User's objection.

In order to exercise this right, please write to the following e-mail address: gdpr.east-europe@erenretail.com

THE RIGHT TO OBJECT TO AUTOMATED PROCESSING, INCLUDING PROFILING: In order to implement this right, the User should click the "unsubscribe" link in any email or message that has been sent to him/her by Gant Poland. In order to object to profiling, please write to the following e-mail address: gdpr.east-europe@erenretail.com .

THE RIGHT TO WITHDRAW CONSENT AT ANY TIME WITH REGARD TO DATA PROCESSING BASED ON CONSENT: The user may withdraw his consent for Gant Poland to process his/her data if such processing is based on consent. The withdrawal of consent does not affect the legality of the processing based on expressed consent before its withdrawal. In order to exercise this right, please write to the following e-mail address: gdpr.east-europe@erenretail.com

THE RIGHT TO SUBMIT A COMPLAINT TO THE SUPERVISORY BODY: The user has the right to contact the data protection authority in order to file a complaint about Gant Poland activities in the area of data protection and privacy. Gant Poland asks Users to write to the following e-mail address before using this right: gdpr.east-europe@erenretail.com

THE RIGHT TO DEACTIVATE COOKIES: The User has the right to deactivate cookies. The default settings of search engines usually accept cookies, however, they can be easily changed in the user's search engine. Many cookies are used to increase the usability and improve the functionality of websites/applications. For this reason, disabling cookies may prevent the User from using certain parts of the Website. For further information, Gant Poland suggests that Users read the information in the "Help" menu in their browser or the information available at http://www.aboutcookies.org

THE RIGHT TO INFORMATION: The user has the right to be informed in a clear, transparent and easily understandable way how Gant Poland uses his/her data and about his/her rights. Gant Poland ensures the fulfillment of this right by publishing the Policy on the Website. All information will be provided by Gant Poland without unnecessary delay - in principle, one month from receipt of the request. If necessary, this period will be extended by another two months due to the complex nature of the request or the number of requests. In any event, within one month of receipt of the request, Gant Poland will inform the User of the action taken and (if applicable) extend the deadline, stating the reason for the delay.

1. Cookies are small text files downloaded to the User's device, used by him/her to browse the Website.

2. Cookies collect data on the User's use of the Website.

3. The main purpose of Cookies is to provide more personal and interactive use of the Website and to study the User's movement on the Website, for example by enabling the User's personal preferences to be set. Cookies are needed in order to facilitate the use of the Website and make it more user-friendly without causing any damage to the device.

4. Cookies used by Gant Poland can be divided in terms of the period which they remain on the device used for browsing, their origin, and their purpose. The Website uses two basic types of cookies: session cookies and persistent cookies. Session cookies are temporary files which are stored on the User's end device until they log out, leave the website, or turn off the software (web browser). Persistent cookies are stored in the user's end device for the time specified in the cookie file parameters or until the user deletes them.

5. The Website uses the following types of Cookies (i) "necessary" Cookies, enabling the use of services available on the Website, e.g. authentication cookies used for services that require authentication on the Website and (ii) "performance" cookies, enabling the collection of information about the use of the Website.

6. Gant Poland does not store sensitive personal data, such as address, password, credit card or debit card details, etc. in the cookies it uses.

7. By default, Internet browsers allow cookies to be stored and accessed by end-user devices. The User is entitled at any time to change the cookie file settings, i.e. change the conditions of storage and access to information gathered by means of cookies. Saved information and access to it does not change the configuration of the end-user device or the software installed on this device.

8. By using this Website without changing the browser settings to disable cookies, the User agrees for cookies to be saved on his/her device and to access to the User's end device. Users can change their web browser settings at any time to disable cookies. Information on changing the settings for cookies can be found at http://www.aboutcookies.org.

9. The User has the right to limit or stop the use of Cookies by his/her web browser by changing the settings to “block cookies” or to requiring prior consent before cookies are saved on the device used to view the Website. In this case, it is possible that the User's use of websites will be less effective. The User may not be able to access some of the content or to use certain functions of the Website, and in extreme cases the correct display of the content of the Website may not be available.

SECURITY

Taking into account the state of technical knowledge, the cost of implementation and the nature, scope, context and purposes of processing and the risk of violating the rights or freedoms of individuals with varying likelihood and severity of risk, Gant Poland applies the appropriate technical and organisational measures which ensure protection of personal data being processed is adequate to the threats and categories of data covered by the protection, in particular, protects the data against it being made available to unauthorised persons, being taken by an unauthorised person, processed in violation of applicable laws and changing, and against its loss, damage or deletion.

Publicly providing information about technical and organisational measures which ensure the protection of processing may undermine its effectiveness, which jeopardizes the proper protection of personal data.

Gant Poland applies in particular the following technical measures to prevent the unauthorised access and modification of personal data sent electronically:

a. Securing the data against unauthorised access.

c. Encrypting data used to authorise the person using the E-Store functionality

d. Access to the Customer Account only after providing an individual login and password.

PLUGIN FACEBOOK

Our website contains a plugin for the social network Facebook (Facebook Inc., 1601 Willow Road, Menlo Park, California, 94025, USA). The Facebook Plugin on the Site is marked with the Facebook logo. This plugin will directly connect the User with the Gant profile on the Facebook server. In such a situation, Facebook may obtain information that the User visited the Website from his IP address. If the User visits the Website while being logged in to his Facebook profile, Facebook will register information about this visit. Facebook does not provide Gant with information about the collected data and how it is used. Gant is also not aware of the purpose and scope of the data collected by Facebook. For additional information on privacy on Facebook, the User should contact Facebook directly or read the privacy policy of the portal at: https://www.facebook.com/about/privacy/ If the User does not agree that Facebook can obtain information regarding his / her visits to the Website, should be logged out of the Facebook account beforehand. Data protection in Google Analytics The website uses the mechanisms of web service analysis of Google Inc. ("Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA"): Google Analytics, Google Double Click and Google Tag Manger. Google Analytics, Google Double Click and Google Tag Manger use cookies that enable an analysis of the use of websites. Information collected by cookies is transferred to Google servers located in the USA and archived. If the IP anonymization function is enabled when using the Website, the User's IP address is shortened by Google. This applies to the Member States of the European Union and other countries listed in the EEA Agreement. Only in exceptional cases is the full IP address sent to a Google server in the USA and shortened there. In this way, the IP anonymization function will be active on the Website. At the request of the website operator, Google will use the collected information to analyze the use of the website, to compile reports on the use of the website and other services related to the use of the internet. The IP address provided by the User's browser as part of the Google Analytics program is not stored together with other Google data. The user can block the saving of cookies in the web browser. However, in this case, you will not be able to fully use all the functions of the website. In addition, the User can block the saving of data collected by cookies regarding the use of the website (including the IP address) and sending them to Google, as well as the transmission of this data by Google by downloading and installing the plug-in available at the following link: https: // tools. google.com/dlpage/gaoptout?hl=pl

CHANGES AND UPDATES

Gant Poland reserves the right to change or update the Privacy Policy and Cookies. The latest version will always be available on the Website. In addition, Users who use the Customer Account service will be informed individually about changes to the Privacy Policy and Cookies.

The Privacy Policy and cookies enter into force on 07/08/2020.