PERSONAL DATA PROTECTION POLICY

Updated: 24/08/2021

WHY THIS PERSONAL DATA PROTECTION POLICY?

This document details the way in which KAPLA France SARL collects and uses your personal data and describes the measures taken by KAPLA France SARL to ensure that this data is protected when you contact us, whether through the Customer Service department or when using the website kapla.com, its online shop or social media.

KAPLA France SARL is the controller of the data collected.

KAPLA France SARL is a limited liability company established under French law, registered in the Commercial and Companies Register of Bordeaux under number 397 736 638, with head office located at 98 avenue de la Garonne, 33410 SAINT-LOUIS-DE-MONTFERRAND, France. KAPLA and the KAPLA logo are trademarks belonging to Tom VAN DER BRUGGEN:

KAPLA is represented by its manager Jan-Daniël VAN DER BRUGGEN.

KAPLA France SARL processes the collected data in accordance with the French legislation and European Union regulations in force regarding matters of personal data protection, in particular the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (‘GDPR’), which entered into force on 25 May 2018.

The data controller and data protection officer is Jan-Daniël VAN DER BRUGGEN, in their capacity as manager of the company KAPLA France SARL.

I. DEFINITION

‘Personal data’ refers to any information that relates to a natural person who can be identified or is identifiable, directly or indirectly, by that information, including the person’s name, identification number, location data, online login details, etc.

II. UPDATING THE PERSONAL DATA PROTECTION POLICY

KAPLA France SARL may modify its Personal Data Policy at any time in order to adapt to new technologies, industry practices or legislative or regulatory requirements, or for any other reasons. The version published on the Website is the version currently in force. If we modify the current confidentiality policy, we will inform you of such modifications.

Therefore, we invite you to regularly check our Confidentiality Policy section.

III. TYPE OF DATA COLLECTED

There are two types of collected information: those that you provide us with willingly and those that we automatically collect.

The data provided willingly comprise:

· The personal data that you convey to us when you open an account, namely: your name, email address, user name and password;

· The personal data that you convey to us when you participate in or sign up for our marketing activities such as contests, namely: your name, email address, telephone number and gender;

· The personal data that you convey to us when you purchase items online. These personal data may comprise: your name, email address, telephone number, postal address, the record of products that you have purchased and details concerning your transaction;

· The personal data that you convey to us when you contact our Customer Service department, for example when you have a question about a product or when you require assistance or a specific service from our Customer Service department. These personal data may comprise: your name, email address, telephone number, information concerning the reasons why you have contacted the Customer Service department and the content of your communications with the Customer Service department.

When you provide us with the personal data of another person, you are confirming, to the extent that the applicable laws permit, that you are entitled to send us these personal data and that you have informed that person that their personal data will be processed for the purposes set out in this confidentiality policy and, if necessary, that you have obtained their consent.

IV. COLLECTION MODALITIES

The information that we automatically collect concern your online experience (kapla.com, social media pages).

Processing your personal data when you are only visiting and checking the Website is limited to browsing data, namely data the transmission of which to the Website is inherent to the functioning of the Website’s management systems and to communication protocols specific to the Internet. The browsing data include, for example, IP addresses of the devices that you use to connect to the Website and other settings relating to the device and the operating system.

In theory, the browsing data such as, for example, the number of visits to and the time spent on the Website, are collected and processed by us exclusively for statistical purposes and in the form of aggregate data in order to measure and improve the functioning of the Website. On account of their nature, the browsing data may come to identify users if they are associated with data held by third parties; however, we do not collect browsing data with the aim of associating them with identified users, except when the aforementioned data may be used with the aim of assigning potential liabilities in the event of computing crimes committed against or through the Website, to the extent provided for by law.

In addition, certain information is collected on this Website through cookies and other monitoring technologies described in our cookies policy.

In accordance with the regulations, we do not collect nor process any data that would reveal racial or ethnic origin, political opinions, religious or philosophical convictions or union affiliation, genetic personal data, biometric personal data for the purposes of identifying a single natural person, personal data concerning health or personal data concerning a natural person’s sexual habits or orientation.

V. PURPOSE OF DATA COLLECTION

These personal data can be collected by us when:

  • You create and manage a customer account on our online shop;
  • You visit our website that may use cookies;
  • You add products to your online basket;
  • You purchase our products online;
  • You make a returns request;
  • You contact the Customer Service department;
  • You participate in contests on our Facebook page;

· You visit, comment or like KAPLA® social media pages;

The information collected will allow us to:

  • Manage your orders, deliveries and returns;
  • Manage your requests and our exchanges;
  • Analyse the visits made to our websites.

VI. DISCLOSURE OF THE DATA COLLECTED

KAPLA France SARL agrees not to publish any data unbeknownst to the user. The data collected by KAPLA France SARL cannot be exchanged, transferred, conceded or sold to a third party in any way whatsoever.

KAPLA France SARL does not share the collected data with third parties except in the following circumstances:

· When you have agreed to share your personal data;

· In the event of a change in ownership of the company, acquisition, collective insolvency proceedings or sale of the company’s assets. The third party in turn would be obliged through this same obligation concerning storage and modification of the data concerning the website’s user;

· To ensure the safety and protect the rights and property of users and third parties;

· In order to conform to a judicial procedure or in other cases where KAPLA France SARL considers that disclosure is legally required, as in the case of a summons or similar judicial procedure.

· When the matter concerns businesses that offer services on behalf of KAPLA France SARL, such as delivering parcels or processing payments; however, these businesses are not entitled to use the personal information for any other purposes than those clearly defined by KAPLA France SARL or in accordance with the law.

VII. KAPLA® AND ITS SOCIAL MEDIA PLATFORMS

KAPLA France SARL has published information and introduction pages on various social media platforms such as Facebook™, Twitter™ and even Instagram™.

If you follow these pages, the personal information that you have shown to be public and accessible from your profile is accessible to KAPLA France SARL.

If you wish to object to KAPLA France SARL having access to this personal information that you have published on your profile (and that is publicly visible), we hereby remind you that the various social media platforms have settings that allow you to control and/or limit access to your data. We also recommend that you carefully and regularly read these social media platforms’ personal data protection policies.

VIII. TRANSFER OF PERSONAL DATA ABROAD

KAPLA France SARL undertakes not to transfer the personal data of its Customers outside the European Union.

In the event that KAPLA France SARL were to do so, it would inform its customers, indicating the measures taken to control this transfer and ensure that the confidentiality of their data is respected.

IX. DATA STORAGE

KAPLA France SARL may keep your personal data for a period:

· Not exceeding ten years from last contact, with regard to customers;

· Not exceeding five years from last contact, with regard to potential customers;

After these time periods, only the data necessary for fulfilling legal obligations (accounting, disputes, etc.) will be kept.

The cookies used by KAPLA France SARL are kept for one year.

X. DATA SECURITY AND INTEGRITY

We have put a secure payment system in place for all orders made on the KAPLA Online Shop (www.kapla.com/shop)

The passwords created by the users in order to create a customer account on the online shop are encrypted.

In no event will KAPLA France SARL or its employees be made aware of these. In the event that the KAPLA France SARL websites are hacked, the passwords cannot be stolen.

Our websites and applications may contain links to other websites which do not belong to us or the monitoring of which we cannot ensure. We will not be held liable for the confidentiality practices of these websites. We encourage you to be vigilant when you leave our websites or applications and to carefully read the confidentiality policies of other websites that are likely to process your personal information.

If KAPLA France SARL becomes the target of a data violation involving your information, we will contact you if your data are at risk of being used inappropriately and if we are obliged to do so in accordance with the law. In certain cases, we may be legally obliged to contact the data protection authorities in the event of violations involving confidential data.

If you notice a fault or problem in our security processes, please do not hesitate to contact us.

XI. YOUR RIGHTS

In virtue of the European regulations known as ‘GDPR’, which have been applicable since 25 May 2018, you will benefit from the following rights:

  • The right to be informed;

- The right of access;
- The right to rectification;
- The right to erasure/the right to be forgotten;
- The right to object to direct marketing, including profiling;
- The right to withdraw consent to the processing of data on the basis of consent;

  • - The right to object to processing on the basis of legitimate interests;
  • - The right to file a complaint with a supervisory authority;
  • - The right to data portability;
  • - The right to restrict processing;
  • - The right to deactivate cookies;
    - The right to define instructions relating to the storage, erasure and communication of your personal data after your death

If you wish to exercise these rights, or if you have any questions about the way in which we collect and process your personal data, please note that at any time you may:

· Check, modify or delete your personal data by logging into your account on the website https://www.kapla.com/shop/.

· Contact us by:

Email

Post: KAPLA France SARL, 98 avenue de la Garonne - 33440 SAINT-LOUIS DE MONTFERRAND, France

In all cases, we will likely ask you for a copy of your ID (that we will keep for one year following date of receipt) and to specify the address to which our response should be sent.