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1. General
1.1 Responsible
Party
The responsible legal entity is: Golchin GMBH
Address: Feldberg Straße 33 79822 Titisee-neustadt, Deutschland, Golchin GMBH
Email: info@newshadrinks.com
Tel.: +4917658379854
The data protection officer of the responsible party is: Mr.
Reza Godratmand
E-mail: privacy@newshadrinks.com
1.2 Scope of Golchin GMBH Privacy Policy
This Privacy Policy applies to all users of information
systems and websites run by all entities belonging to Golchin GMBH.
The following rules describe how Golchin GMBH handles
information relating to an identified or identifiable person (Personal Data)
for services performed through all Golchin GMBH information systems and
websites (Systems).
Users (consist of all individuals around the world, who
connect to and use Systems) expressly consent to the Processing of their
Personal Data as described in this Privacy Policy. Processing has the meaning
of any operation with Personal Data, irrespective of the means applied and the
procedure, and in particular the collection, transfer, storage, use, revision,
disclosure, archiving or destruction of Personal Data.
This Privacy Policy is effective on 21st March 2019.
Golchin GMBH may amend this Privacy Policy at any time by posting the amended terms on Golchin Systems. All amended terms automatically take effect 30 days after they are initially posted and disclosed. The continued use of the Systems after any such changes shall constitute the consent of the User to such changes.
1.3 Principles of Processing Personal Data
1.3.1 Purpose and Scope of Processing
Our primary purpose in collecting Personal Data is to provide Users with safe and efficient services. So, Protection of your personal data on our website is important to us. As a rule, we only process the personal data of our users to the extent required in order to provide a functional website as well as our services related to our Terms and Conditions.
1.3.2 Data Deletion and Storage Period
Regardless of possible revocation of your consent, we process and store your personal data as long as and to the extent required in order to satisfy the respective purposes.
1.3.3 Recipients
Golchin GMBH will only pass your personal data to other
third parties, if it is necessary to carry out your payment transaction, your
purchase or orders, for example as part of order processing, customer data is
transmitted to the systems of third parties to transact payments (with banks,
credit card reservation or bookings).
We do not sell or rent Users’ Personal Data to third parties
for their marketing purposes without Users’ explicit consent. If Users do not
wish to receive marketing communications from Golchin GMBH, they simply
indicate their preference at any time via e-mail to: privacy@newshadrinks.com
Golchin GMBH may also share Users’ Personal Data with:
- Fulfillment centers
- Service providers under contract
who help with the business operations (such as for example fraud
investigations, bill collection, customer support, support from sales
consultants).
- Other third parties to whom
Users explicitly ask Golchin to send their Personal Data.
- Law enforcement agencies, other governmental agencies or third parties in response to a request for information relating to a criminal investigation, alleged illegal activity or any other activity that may expose Golchin or Users to legal liability. The Personal Data Golchin disclose may include User ID and User ID history, name, city, telephone number, email address, or anything else that Golchin deems relevant.
1.4 Rights of the Data Subjects
If we collect or process personal data on this website, then
you are the data subject within the meaning of the EU General Data Protection
Regulation [GDPR].
In this case you have the right of access, the right to rectification and erasure of your data, the right to restriction of processing, a right of objection to processing and the right to data portability. In this case, you are most welcome to email us at privacy@newshadrinks.com
1.5 Revocation of Declarations of Consent
If you have given us your consent to process your personal
data, then you may revoke such consent at any time via e-mail to:
privacy@newshadrinks.com
A revocation shall not affect the legality of the processing carried out up to that point.
2. Processing
of Personal Data
2.1 Provision of the Website
Each time our website is accessed, data and information are
automatically processed by the computer system of the invoking computer.
The following data is collected:
- Name of your Internet service
provider
- IP address
- Date and Time of access
- The browser type and version
- The website from which you visit
our website
This information is evaluated for statistical purposes and
subsequently deleted. The individual user remains anonymous.
Furthermore, our website responds to browser do-not-track
signals.
2.2 Contact Form and Email
In order to improve our customer service, on our website we
provide you with a contact form which can be used to contact us electronically.
Any processing of personal data is only used to handle your request.
If you use email to contact us, the data entered will be
transmitted to us and stored. This data includes: name, first name, postal
address, e-mail address, telephone number, information about your interest(s).
2.3 Online Office – Sign up Process
2.3.1 Purpose of the Processing
Your data which you communicate to us via the Registration
form, will be stored and used exclusively for purposes connected with the
registration and processing of your interest in cooperating with Golchin GMBH.
While you order, personal information is gathered from you
by Golchin. In this context your information is stored safely by Golchin; this
means you have the advantage of not having to enter your personal data again
with every order. The information includes in particular your name, email
address, tel. number, mobile number, address and information on invoices. The
information you provide here is exclusively used to simplify your order
process, for administrative purposes and in-house analyses.
Users agree that Golchin GMBH may also use their Personal
Data to:
• The execution of your
purchases, transactions or other orders.
• Provide the services and
customer support you request;
• Resolve disputes, collect fees,
and troubleshoot problems;
• Customize, measure and improve
Golchin services, content and advertising;
• Tell Users about our products, targeted
marketing, service updates, and promotional offers based on their communication
preferences
• Send marketing communications
via email or mobile (which Users may choose not to receive at any time by
following the instructions provided with the communication)
• Compare Personal Data for
accuracy, and verify it with third parties.
• The following as long as
Golchin has received your consent:
- Using the information stored in your user profile, to
offer you the possibilities of individual services and optimal use of our
Website.
- In order to provide you with individual offers and
information personally interesting to you. Of course you also have an
opportunity to tell us that you do not want (or no longer want) to be sent such
offers and/or information. We will, of course, respect that.
2.3.2 Collection and Processing of Registration Data
Online sign-up requires that certain personal data indicated
with mandatory fields in the respective online registration form be provided.
Furthermore, you have the option of sending us further details.
If you choose to provide us with Personal Data, then by
clicking on the corresponding checkbox you consent to the collection, storage,
transfer and use of the data in accordance with this data protection
declaration.
Once you enter your registration data and click on the
“Submit” button, they will be transmitted and collected on a server in Germany;
the server is now hosted and administered by a service provider commissioned on
our behalf and even later elsewhere in the world where Golchin has facilities
in compliance with applicable data protection laws and regulations, even if the
level of legal protection is lower than in the User’s country of residence.
Golchin GMBH will take all reasonable steps in order to
ensure that your data is handled carefully and completely.
However, for this purpose your registration data must be truthful, complete and up-to-date. Therefore, please inform us immediately with regard to any changes in your data. You may review the data that you have entered at any time and make any changes by revising your data or adding information or send us a request to do so.
Golchin Gmbh may collect and store
the following personal information, including Personal Data:
- Email address, physical contact
information, and (depending on the service used) sometimes financial
information, such as credit card or bank account numbers;
- Shipping, billing and other
information Users provide to purchase or ship an item;
- Correspondence through Systems,
and correspondence sent to Golchin GMBH;
- Other information from Users’
interaction with Systems, services, content and advertising, including
computer/device and connection information, statistics on page views, traffic
to and from the sites, ad data, IP address and standard web log information;
- Additional information Golchin
ask Users to submit to authenticate themselves (e.g. we will ask Users to send
copies of ID, or passport to verify their identity and personal details):
- Additional information may be
collected as per applicable policy.
2.4 Google Analytics
We use Google Analytics to understand how visitors engage with our sites and apps. This means that when you visit our website or use one of our mobile applications your browser automatically sends certain information to Google. This includes, for example, the web address of the page that you're visiting and your IP address. You will find the details of how the Google technology collects and processes data following this link https://www.google.com/policies/privacy/partners/.
3. Accessing,
Reviewing, Changing and Deleting Users’ Personal Data
3.1. Accessing, Reviewing and Changing Personal Data
Users can see, review and change most of their Personal Data by signing in to Systems (within the personal, password-protected area.). Generally, Golchin will not manually modify Users’ Personal Data because verifying their identity remotely may prove difficult. Thus, it is Users’ responsibility to update promptly their Personal Data if it changes or is inaccurate.
Should you wish not to receive any messages or information
about offers and special promotions and Newsletter from Golchin, which you had
previously agreed to receive, simply send an email to us at the following
address: privacy@newshadrinks.com
3.2. Deletion of Data
You also have the right upon request to delete your data
stored with us free of charge and at any time. To delete them, please go
through “Termination of Distribution” menu in your virtual office.
If you do not arrange for your data to be deleted, then your
data will be processed until the day we receive your “Termination of
Distribution” request.
Golchin do retain Personal Data from closed accounts to
comply with law, prevent fraud, collect any fees owed, resolve disputes,
troubleshoot problems, assist with any investigations, and take other actions
otherwise permitted by law.
4. Security
Information
Through technical and organizational measures
we protect your data against unauthorized access, loss and destruction.
We treat Personal Data as a valuable asset and preserve it
with various methods (encryption, passwords, physical security, etc.) to
protect Users’ Personal Data against unauthorized access and disclosure.
However, third parties may unlawfully intercept or access transmissions or
private communications between Users and Systems. Therefore, although Golchin
deploy significant effort to protect Users’ privacy, Golchin do not promise
that Personal Data or private communications will always remain private.
Users’ password is the key to their account. Users shall use
unique numbers, letters and special characters, and do not disclose their
password to anyone. If Users do share their password or their Personal Data
with others, they shall remember that they are responsible for all actions
taken in the name of their account. If Users lose control of their password,
they may lose substantial control over their Personal Data and may be subject
to legally binding actions taken on their behalf. Therefore, if Users’ password
has been compromised for any reason, they should immediately notify Golchin and
change their password.