By using the website www.vtsgroup.com and the services offered by VTS Group companies, you entrust us with your personal data. We want you to know why and how we process it, what your rights are and how we ensure its security.

In this policy, we explain:

• Who the controller of your data is,
• What data we collect and for what purpose,
• On what legal basis we process data,
• How long we store it,
• How you can exercise your rights.

Protecting your privacy is our priority, which is why we make every effort to ensure that data processing complies with applicable regulations, including the GDPR. If you have any questions, you will find our contact details and the details of the Data Protection Officer at the end of this document.

Personal data is any information about you that allows you to be identified, either directly (e.g. name, surname, e-mail address) or indirectly (e.g. information about your activity on the website or in the application). A full list of the data processed can be found in section 4.

GDPR is Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, which regulates the rules for the protection of personal data in the EU. GDPR imposes specific obligations on us in relation to the processing of your data and guarantees the exercise of your rights. You can find more information about your rights in Chapter 11.

Websites include, among others, the website available at https://vtsgroup.com/ and all other platforms and tools offered by VTS Group companies through which we provide our services and collect user orders.

A web and mobile application that allows remote control of VTS smart devices. It allows you to manage connected devices, including controlling their operation, modifying automation settings and monitoring technical parameters. Full information about the data collected and how it is used can be found in the Appendix in Part A.

A web application for selecting ventilation and air conditioning units, certified by Eurovent. It allows you to create designs by integrating with CAD and REVIT tools as well as CRP, ERP and WMA systems. The application is available from any device with a web browser at https://vtsgroup.com/pl/climacad. For more detailed information on the functionalities of ClimaCAD OnLine 4, please refer to the Appendix in Part A.

Online Shops are available at the following addresses:

§  https://eshop.vtsgroup.com/ - sales are conducted by VTS Plant sp. z o.o.; and

§  https://eshopahu.vtsgroup.com/ - sales are conducted by VTS sp. z o.o.

 

Through the Online Shops, it is possible to purchase products offered by companies from the VTS Group. More detailed information about the functionality of the shops can be found in the Appendix in Part A.

The website (http://www.homer-ventilation.com/) is used to obtain information about recuperators offered by VTS and to contact the company via a dedicated contact and service form.

The HOMER Connect mobile application allows you to connect and operate recuperators via Bluetooth technology or a wireless local area network (WLAN). The application allows you to control the operating modes of recuperators, view operating parameters and access information on the operation of recuperators.

For more detailed information on the processing of personal data, please refer to the Appendix in Part A.

2.1.   Depending on the type of service provided, the controller of your data is the relevant company from the VTS Group ("Controller"). Detailed information on this subject can be found in the Appendix to the Privacy Policy.

2.2.   For users of the website https://vtsgroup.com/, the Controller of personal data is VTS sp. z o.o. with its registered office in Gdańsk.

2.3.   For users placing orders via the website https://vtsgroup.com/, the Controller of personal data is VTS Polska sp. z o.o. with its registered office in Warsaw.

2.4.   For users of the mHMI and ClimaCAD OnLine 4 (CCOL4) applications, the Controller of your personal data is VTS sp. z o.o. with its registered office in Gdańsk.

2.5.   For users of the Online Shop available at https://eshop.vtsgroup.com/, the Controller of personal data is VTS Plant sp. z o.o. with its registered office in Gdańsk.

2.6.   For users of the Online Shop available at https://eshopahu.vtsgroup.com/, the Controller of personal data is VTS sp. z o.o. with its registered office in Gdańsk.

2.7.   For users of the website http://www.homer-ventilation.com/ and the HOMER Connect mobile application for recuperators, the personal data controller is VTS Plant sp. z o.o.

 

We will use your data for various purposes, but only when justified. By using our websites, applications, services, and shopping platforms, you accept the purposes of processing your data, which we present below:

§  Performance of a contract:

We process your data in order to conclude and perform a contract for the provision of services (e.g. use of our Websites, Mobile Application, Web Applications, website or mobile application related to Recuperators, or conclusion of sales contracts in Online Shops). This allows you to use our solutions and us to provide them in a proper and effective manner.

§  Legal obligations:

We fulfil our obligations under the law, including in the areas of taxation, accounting and data security.

§  Access to services:

We process data to enable you to use the available functionalities of our Websites, Applications, website or mobile application related to Recuperators and Online Shops – including account registration, logging in, viewing content, modifying settings and contacting us via forms, chat, e-mail or telephone.

§  Participation in promotions:

We provide you with the opportunity to participate in competitions, lotteries and promotions organised by us.

§  Newsletter and communication:

We process your data so that you can receive our newsletter and other marketing information, thanks to which you will be up to date with our offer, news and promotions.

§  Contacting us:

We enable you to contact us directly through various channels, such as forms, chat, e-mail, letter or telephone, which allows us to respond to your enquiries and support you in using our services.

§  Service development:

We analyse your activity in order to continuously develop our services and improve their quality and comfort of use of our Websites, Applications, webpage or mobile application related to Recuperators and Online Shops.

§  Opinions and satisfaction surveys:

We want to know your opinion about our services and products – this may mean contacting you with a request to participate in a satisfaction survey.

§  Security:
We process your data to ensure the security of our services and to protect our rights and the rights of our customers.

§  Claims and defence:

In some cases, we use data to pursue our claims or defend ourselves against claims, which is necessary to protect our legal and economic interests.

§  Marketing:

We may use your data for marketing purposes – both our own and those of other companies in the VTS Group and cooperating entities. Detailed rules for processing in this regard can be found in the Appendix in Part A.

§  Social media activity:

We maintain our accounts on social media platforms in accordance with the rules of the operators of these platforms. Through these accounts, we inform you about our activities, events, products and services, and build and maintain relationships with our community. We use data from social media for communication (e.g. comments, messages) and to create activity statistics, which is our legitimate interest.

Detailed information on the purposes, scope of processing, legal basis and retention periods for your personal data is described in the Appendix to the Privacy Policy. We will also provide additional information on the processing of your data at the time of collection.

 

We collect your personal data only to the extent necessary, depending on the type of services we provide, the products we sell and the information you voluntarily provide to us. The type of data collected may vary depending on the context. The detailed scope, purposes, legal bases and retention periods for each category of data are set out in the Appendix to the Privacy Policy.

§  Contact and identification data:

Name and surname, e-mail address, telephone number, postal address. In the case of business services – additionally, company name, tax identification number, statistical number and other identification data related to business activity.

§  Authentication data:

Passwords, verification codes and other information securing access to your account.

§  Financial data:

Bank account numbers, credit or debit card details necessary to process payments for our services or products in Online Shops.

§  Data collected through registration, forms and surveys:

Information you provide when registering with our systems, participating in programmes, competitions or events. This may include identification data, contact details and information about your preferences and interests.

§  Data provided when submitting enquiries:

The content of messages sent via contact forms, chat, e-mail or other communication channels.

§  Data collected automatically:

When you use our Websites, Applications (mHMI, ClimaCAD OnLine 4), website or mobile application related to Recuperators and Online Shops, we automatically collect technical data that helps us ensure the proper functioning of our solutions, including:

o   IP address,

o   System log information and activity history,

o   Device and connection data, such as browser type and version, time zone settings, geographical location (e.g. region, country code),

o   Information collected using cookies and other similar technologies.

§  Data related to the performance of contracts:

In order to conclude and perform contracts for the provision of services or sale of products, we process data necessary for:

o   User account management (e.g. registration date, location data),

o   Executing transactions, delivering shipments and providing services (e.g. identification data, payment information).

§  Data related to usage:

Behavioural information, such as how you navigate our Websites, Applications, website or mobile application related to Recuperators or Online Shops, most frequently used features and purchasing preferences (e.g. wish list, interests).

§  Technical data:

Device and connection information, such as IP address, browser type and version, geographical location (e.g. region, country code, time zone settings), advertising identifiers, cookie or tracker data.

§  Audio and video data:

Audio recordings, photos or images, if you share them when participating in our events or contacting us (e.g. via chat or video conference).

§  Other data:

Any additional information you provide to us through our Websites, Applications, website or mobile application related to Recuperators, Online Shops or other products and services (e.g. content of messages in contact forms, comments in chat).

§  Data processed in Online Shops:

As part of the Online Shops, we process the personal data of Buyers that is necessary to conclude and perform the Sales Agreement, including:

o   First and last name,

o   E-mail address,

o   Contact telephone number,

o   Delivery address (street, house number, flat number, postcode, town, country),

o   Address of residence or business/registered office (if different from the delivery address).

o   For Buyers who are not consumers, we also process the company name and tax identification number (VAT number). The scope of required data is always indicated on the website of the Online Shop and in the Shop Regulations.

§  Data processed in the mHMI Application:

When you use the mHMI Application, which is linked to your account, we collect the following data:

o   Account information:

Account name, e-mail address, country, company name, address, NIP number, telephone number – data necessary to conclude a user agreement.

o   Location information:

Device location data, such as region, country code, city code, time zone and language settings.

o   Log information:

IP address, system logs, activity history, and crash information – data necessary for monitoring application performance and troubleshooting.

o   Authentication data:

Password and verification code, necessary to secure your account and access to the service.

o   Automation and scene settings information:

Automation and scene name, conditions and list of actions, effective time period setting, execution result notification setting, and settings to enable or disable automation.

o   Feedback:

The content of your feedback, contact details, and error logs that you provide to us when you give us your opinion or report problems.

o   Device information:

Data obtained from your device, necessary to display device information in the application.

Data may be collected directly from you when you register with our systems, use our services or fill out forms. It may also be supplemented with data from other sources, such as public records or data obtained from third parties that provide analytical services.

§  Our services are intended only for adults who are 18 years of age or older. We do not permit persons under the age of 18 to use our services.

§  VTS does not collect personal data from minors or send promotional materials to persons in this category.

§  If we learn that a minor's data has been provided, we will take immediate action to delete it.

§  If a parent or guardian has reason to believe that a minor's personal data has been submitted without their consent, please contact us to ensure that this data is deleted immediately.

 

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We do not store your data for longer than is necessary to fulfil the purposes for which it was collected, taking into account its scope, nature and possible risk of harm.

The storage period for your data depends on the purpose for which it was collected and the legal basis for its processing. We take into account:

§  If the data is processed on the basis of consent (e.g. for marketing purposes), it will be stored until consent is withdrawn.

§  In the case of data processing for the purpose of performing a contract, the data is stored for the duration of the contract and for the limitation period of claims arising from it.

§  If the data is processed on the basis of legal obligations, we will store it for as long as required by law.

§  When processing data on the basis of a legitimate interest, the data will be stored for the duration of that interest.

§  When using the mHMI application, ClimaCAD OnLine 4 and Online Shops, data such as account information, logs, authentication data, automation settings and technical data will be stored until the user deletes their account. In the case of processing temporary logs created during remote diagnostics related to reported failures, the data will be deleted within 30 days at the latest.

§  After closing your account, your data will be irrevocably deleted or anonymised, usually within 6 months at the latest. During this period, the data may still be processed solely for the purpose of fulfilling legal obligations or protecting our legitimate interests (e.g. pursuing claims).

§  We will delete your data when it is no longer necessary for the purposes for which it was collected.

§  Some categories of data may be deleted earlier if they are no longer needed for a specific purpose, but others, such as those related to legal obligations, may be stored for a longer period.

§  If your data is processed for marketing or advertising purposes, it will be stored until you withdraw your consent or unsubscribe from advertisements (including commercial communications), in accordance with the settings available in your account in the Applications or Online Shops.

 

 

We only share your personal data with other entities when it is necessary to provide our services, perform contracts, comply with legal obligations, or when we have a legitimate interest. We use appropriate safeguards to protect your data when it is transferred.

Your data may be shared internally within our organisation to support the provision of services and improve the quality of our solutions.

 

Your data may be transferred to other companies within the VTS Group, including franchisees of VTS Group companies that support us in the development of services, business analysis, security and customer service. The transfer of data between entities within the VTS Group enables us to provide the comprehensive services you use. We never transfer more data than is necessary to achieve a specific, above-mentioned purpose, and each data recipient undertakes to comply with the principles of this Policy and the GDPR.

 

In order to provide our services, we use external entities that process your data in accordance with our instructions. These may include:

§  IT service providers, including hosting and IT infrastructure maintenance systems,

§  Entities providing accounting and legal services, debt collection and factoring services,

§  Entities specialising in maintenance and customer service, including shipping companies and contact centres.

In order to improve our services and support our marketing activities, we share selected data with analytics and marketing service providers, such as Google Analytics and social media monitoring tools. More detailed information on the marketing and analytics tools we use can be found in the Appendix in Part A.

The legal basis for data processing by these tools depends on their configuration:

1.      Consent (Article 6(1)(a) of the GDPR) – if the tool stores cookies on your device or uses similar tracking technologies that enable identification or profiling. Consent is obtained by our cookie banner; you can withdraw it at any time in your Privacy Settings.

2.      Legitimate interest (Article 6(1)(f) of the GDPR) – we only use this when:

§  the data is immediately pseudonymised/anonymised (e.g. shortened IP address, no transfer of unique user IDs);

§  we use it exclusively in the form of statistical reports to evaluate website performance, errors or aggregated trends.

 

Data may be transferred to providers based outside the EEA (e.g. Google). In such cases, we apply the measures required by the GDPR (adequacy decisions, standard contractual clauses, additional technical safeguards) – details in section 7.

This allows us to analyse how our Websites, Applications, webpages and mobile applications relating to Recuperators and Online Shops are used and to optimise our products and services.

 

In order to execute payment transactions, your data is transferred to payment service providers or other entities handling electronic and card payments. This entity becomes a separate controller of your data and processes it only to the extent necessary to execute the payment and to verify and identify the customer.

 

In cases provided for by law or in situations where the competent authorities request the disclosure of data, we may disclose selected information about you. We will do so in accordance with applicable law and only to the extent necessary to comply with such a request.

 

When using Online Shops:

§  If you choose courier delivery, your personal data (such as delivery address and contact details) may be transferred to the selected carrier or intermediary handling deliveries on behalf of the Controller.

§  If you use electronic or card payment methods, your data necessary for the payment to be made is transferred to the selected entity handling these payments.

 

Your data may also be transferred to the following entities:

 

§  Business partners: Entities with whom we cooperate, such as banks or other companies that enable faster and more efficient payments and the execution of sales contracts. Such entities control and manage personal data in accordance with the contract.

§  Industry, accreditation and professional organisations: Data may be transferred to organisations that support access to our services or monitor activities within industry programmes.

§  Entities involved in corporate transactions: In the event of a merger, acquisition, sale or restructuring of the company, your data may be transferred to entities involved in such transactions.

§  Other recipients with your consent: In addition to the disclosures described above, your data may be shared with third parties when you voluntarily consent or instruct us to do so.

 

In all cases, we ensure that the data provided is used only for the purposes for which it was made available, and that access to it is restricted to those entities necessary to perform specific tasks.

 

We transfer your personal data outside the European Economic Area (EEA) only when necessary to provide our services or when required by law, and always with an adequate level of protection in accordance with GDPR requirements.

Your personal data may be transferred to countries outside the EEA that the European Commission has recognised as providing an adequate level of data protection. Where countries to which personal data is transferred do not offer such a level of protection, we apply additional safeguards, such as Standard Contractual Clauses approved by the European Commission. In such cases, data is transferred only to the extent necessary to achieve specific purposes.

When transferring data outside the EEA, we take special precautions, including:

§  We minimise the scope of data transferred outside the EEA.

§  We verify that service providers based outside the EEA guarantee a high level of personal data protection in accordance with EU regulations.

§  We use model contractual clauses and other safeguards to ensure that your data is protected to the same level as in the European Union.

In situations where data transfer outside the EEA is necessary (e.g. for the provision of payment, hosting or analytical services), your personal data is only transferred to entities that process it in accordance with our instructions and on the basis of contracts concluded in accordance with the requirements of the GDPR.

We transfer your personal data outside the EEA when using the following tools on our websites:

 

• Google Tag Manager, Google Analytics, Google Merchant, Google Ads – the provider of these tools (Google Ireland Limited, based in Ireland) transfers personal data to other entities based outside the EEA:

-       Google UK Ltd based in the United Kingdom, Google Israel Ltd. based in Israel, TMJ, Inc. based in Japan, SCSK Serviceware Corporation based in Japan, K.K. Teledirect Japan based in Japan, Jellyfish U.K. Limited based in the United Kingdom, Accenture Japan Ltd. based in Japan – personal data is transferred to entities based on adequacy decisions;

-       Google Peru S.R.L. in Peru, Google Kenya Limited in Kenya, Google FZ LLC in the United Arab Emirates, Google Colombia Limitada in Colombia, Google Brasil Internet Ltda. in Brazil, Google Australia Pty Ltd. in Australia, Google Asia Pacific Pte. Ltd. in Singapore, Google Argentina S.R.L. in Argentina, Google Infraestructura Argentina S.R.L. in Argentina, GOC Services India Private Limited in India, GOC Philippines, Inc. in the Philippines, TTEC Brasil Serviços Ltda. in Brazil, TDCX (MY) Sdn. Bhd. in Malaysia, Regalix India Private Limited in India, Regalix Inc. in the USA, Intelenet Global Services Private Limited in India, HCL Technologies Limited in India, HCL (Brazil) Tecnologia da Informação Ltda in Brazil, HCL America Inc. in the USA, GlobalLogic Technologies Limited in India, GlobalLogic Inc. in the USA, EPAM Systems Inc. in the USA, Concentrix Daksh Services India Private Limited in India, Concentrix Solutions Corporation in the USA, Competence Call Centre İstanbul Çağrı Merkezi Hizmetleri Anonim Şirketi in Turkey, Cognizant Technology Solutions Philippines, Inc. in the Philippines, Cognizant Technology Solutions India Private Limited in India, Cognizant Technology Solutions de Mexico S.A. de C.V. in Mexico, Cognizant Technology Solutions de Argentina SRL in Argentina, Cognizant Serviços de Tecnologia e Software do Brasil S/A in Brazil, Atento Argentina S.A. in Argentina, Accenture Solutions Private Limited in India, Accenture LLP in the USA, Accenture Inc. in the Philippines, Accenture Co. Ltd. in Taiwan – personal data is transferred to entities based in the USA on the basis of standard contractual clauses issued by the European Commission.

• Meta Pixel – the provider of this tool (Meta Platforms Limited based in Ireland) transfers personal data to other entities based outside the EEA:

-       Meta Platforms Inc., based in the USA ─ personal data is transferred to an entity based in the USA listed under the Data Privacy Framework programme based on the European Commission's adequacy decision;

-       Andale Inc., Greater Kudu LLC, Goldframe LLC, Meta Operations LLC, Morning Hornet LLC, Offprints LLC, Omanyte LLC, Paile LLC, Raven Northbrook Services Limited, Scout Development LLC, Siculus Inc., Sidecat LLC, Stadion LLC, Starbelt LLC, Woolhawk LLC, Vitesse LLC, Winner LLC d/b/a Ernst LLC based in the USA ─ personal data is transferred to entities based in the USA in accordance with standard contractual clauses issued by the European Commission.

• LinkedIn Insight Tag – the provider of this tool (LinkedIn Ireland Unlimited Company based in Ireland) transfers personal data to other entities based outside the EEA. Personal data is transferred based on adequacy decisions of the European Commission and standard contractual clauses issued by the European Commission.

 

All information we receive about you is stored on appropriately secured servers. We continuously assess the security level of our network and monitor internal procedures to:

• protect your data from accidental or unauthorised loss, access or disclosure,
• identify potential risks to the security of our systems,
• minimise threats through regular testing and risk assessment.

All payment-related data is encrypted using SSL technology, which guarantees its confidentiality during transmission.

In order to maintain and provide our services, we use external providers who process personal data on our behalf. We only work with entities that:

§  guarantee a high level of data protection in accordance with the provisions of the GDPR,

§  process data only to the extent necessary to perform specific tasks,

§  operate on the basis of data processing agreements that clearly define the obligations of both parties and the security measures applied.

Our Websites, Web Applications and Mobile Applications may contain links to third-party websites or applications. We have no control over the privacy policies of these websites or applications; their providers are solely responsible for their own regulations. We encourage you to review the privacy policies of each website you visit.

As part of providing our services, we may contact you by email and text messages. The purpose of these communications is to:

§  inform you about the status of services,

§  provide information related to the performance of contracts, including important communications regarding the functioning of our Websites, Applications, website or mobile application related to Recuperators and Online Shops.

Sending these messages is necessary for the proper functioning of our services (e.g. information about changes to the terms and conditions, important system updates, technical problems, etc.), so you cannot opt out of receiving them.

From time to time, we may contact you to find out how you rate our services and products. Such activities are undertaken sporadically and are aimed at continuously improving our offer. You have the right to object to participating in satisfaction surveys in accordance with the information contained in Chapter 11.

If you use the contact form or another communication channel (chat, e-mail, telephone), we will use the data you provide to answer your questions, consider your complaint or present an offer, depending on the purpose of your message.

We will use your e-mail address and telephone number, as well as the mHMI Application on the device you use, to send you direct marketing communications (e.g. e-mails, push notifications, text messages or phone calls) to inform you about our products, promotions and news.

§  Marketing communications are sent only on the basis of your consent, which you can give during registration or through the settings in our Websites or Applications.

§  You may withdraw your consent to marketing communications at any time by using the unsubscribe link included in each email or through the consent management panel available in the Applications. If you have any problems withdrawing your consent, please contact us via the Contact Form.

We use profiling to achieve our marketing and analytical goals and to optimise the functioning of our services, including account management in Online Shops, Web Applications, Mobile Applications, the website or mobile application related to Recuperators, and other Websites. This means that through the automatic processing of your personal data, we analyse selected information about your activities, preferences and behaviour. This allows us to:

§  Better tailor content and offers to your individual needs,

§  Forecast future activities and adapt our services,

§  Improve our solutions by enhancing the quality of our services.

The results of profiling do not have any legal effect on you and do not significantly affect your situation. You have the right to object to profiling, especially for marketing purposes, in accordance with the information contained in Chapter 11.

The GDPR guarantees you specific rights in relation to the processing of your personal data. Below we present what rights you have and how you can exercise them:

You have the right to check whether we process your personal data and, if so, to receive a copy of it and information about the purposes of processing, categories of data, recipients or categories of recipients, and storage periods.

You have the right to request that incorrect, incomplete or outdated data be corrected. In some cases, we may require verification of the new data you provide to us.

You may ask us to restrict the processing of your data, for example, when:

§  you contest its accuracy,

§  the processing is unlawful,

§  we no longer need your data, but you need it to assert your claims or defend against claims,

§  you object to further processing (in such situations, we will check whether we have overriding grounds to continue).

You have the right to object to the processing of your data, especially when the processing is based on our or third parties' legitimate interests, including for marketing purposes. You may object at any time, which may result in the cessation of further processing of your data for marketing purposes.

You have the right to request the erasure of your personal data if:

§  it is no longer necessary for the purposes for which it was collected,

§  you withdraw your consent (if this is the only basis for processing),

§  you effectively object to their processing,

§  it must be erased under the law.

Please note that in some cases we have to continue processing the data in order to comply with legal obligations.

You have the right to receive your personal data that you have provided to us in a structured, commonly used, machine-readable format and to transfer it to another controller if the processing is based on consent or in the performance of a contract and the data is processed by automated means.

If the processing of your data is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of data processing that took place before withdrawal.

To exercise your rights, you can contact us in one of the following ways:

• Email: IOD@vtsgroup.com
• Telephone: +48 510 130 633
• Post: rue de L'Industrie 20, L-8399 Windhof, Luxembourg
• Contact form: available on our website

In addition, you can exercise your right to object to the processing of marketing data by clicking on the unsubscribe link in the emails sent to you or by changing the notification settings in your account in the Applications or Online Shops.

The fulfilment of your rights is usually free of charge. We endeavour to respond to requests within one month of receipt. If your request is particularly complex or repetitive, the processing time may be extended, in which case we will inform you in advance.

If you believe that we are violating the regulations regarding the protection of your personal data, you have the right to lodge a complaint with the competent supervisory authority. In matters related to data processing, you can contact the President of the Personal Data Protection Office at ul. Stawki 2, 00-193 Warsaw.

For further information on the protection of your data or to exercise your rights, please contact us:

• Contact form: available on our website.
• Email: IOD@vtsgroup.com
• Telephone: +48 510 130 633
• Postal address:

rue de L’Industrie 20,

L-8399 Windhof,

Luxembourg

If you have any questions about the processing of your personal data or would like to exercise your rights, please contact us.

13.1.    We may amend or update this Privacy Policy to reflect changes in the law or our practices. Any changes will be posted on our website, on the Websites, in the Web Applications, on the webpage or in the mobile application for Recuperators, Online Shops and Mobile Applications. If you have provided us with your e-mail address, we will also notify you of significant changes by e-mail. Such changes to our Privacy Policy will take effect on the date specified in the announcement or on the Website.

13.2.    If you do not agree to the changes in the Privacy Policy, you have the right to close your account in the Internet Applications, Online Shops or Mobile Applications. You will find the option to close your account in your account settings.

13.3.    In matters not covered by this Policy, we apply the provisions of the GDPR and other applicable laws.