Privacy Policy

General provisions

In our Privacy Policy you will find answers to the most
frequent questions about how we collect, use and store information about you.
If you have questions, comments or complaints about how we collect, use and store
information about you, the Company is ready to assist you. If you need help, please contact
us by email info@sinfulcars.com
By registering on the website www.sinfulcars.com, you provide your personal
data to the Company and you give us the right to process them in the scope, manner and
purpose indicated in this Policy (hereinafter the Policy) and/or the Rules for the sale and
purchase of goods (hereinafter the Rules).
Please note that both the Policy and the Rules may be amended, completed and updated.
Personal data is any information that can be used to identify a person, as well as any
information about a person who has already been identified.
The Company respects your privacy, and the security of your personal data is our
priority. The Company shall take appropriate organizational and technical measures to
ensure that your personal data is always safe and that the processing operations comply with
the requirements of the data protection legislation and the Company’s internal procedures.
The Company collects and manages your personal data listed in these Rules on the
following legal grounds:
– Your consent;
– Company’s legitimate interest;
– Enforcement of legal obligations arising and applicable to the Company.
Under the terms and conditions stipulated by applicable law, one or more of the above legal
bases may apply to the processing of your personal data.
1. What of your data we process, and why?
1.1. Registration, verification, administration and communication registration
Registration

By registering and accepting the Rules, you provide us with the following personal data.
Submission of certain registration data is necessary and you will not be able to use the
Services without providing them. By signing up, you confirm that the personal data you
provide is accurate and correct, and that you are at least 16 years of age. We are not liable for
inaccurate, incomplete or misleading submission of your data.
Personal data:
Data categories Your name, surname, address, e-mail address, phone number, address, internet
protocol (IP) address, device information.
Legal basis for
data processing
Your consent to use the Services under the terms and conditions provided for in
the in the Policy and/or the Rules
Term of data
processing
For the duration that you use the Services. We can keep your consent and proof
of it for a longer period if necessary so that we can defend against any claims,
lawsuits or actions brought against us.
How and for what purposes do we use your personal data?
Using your personal data, we create a unique profile on our Websites to identify you as a
registered Website user and which will give you access to the Services provided to registered
users in accordance with the Rules and/or the terms and conditions provided for in this
Policy.
By using your personal data, we also can recognize you, for example, if you wish to update or
edit your data, or contact us regarding the provision of certain personal information, the
implementation of rights related to the processing of personal data, etc. We also use contact
details provided in your questionnaire (email, telephone number) to communicate with you,
including, to respond to your requests, comments, to provide important information about the
Services to you, their provision and (or) changes in this Policy. We contact you if you have
forgotten to accept your purchases or we have detected any problems with transactions, etc.
It is very important that the personal data you provide to us is accurate and correct. If you
provide incorrect (false) data, forget them or do not update the changed data, it may be
difficult for us to ensure the provision of the Services, or there may be problems in exercising
your rights. We will under no circumstances be liable for any damage caused to you due to
incorrect or incomplete personal data. If the data you submit to us change, you must inform
us immediately by replacing the relevant data on the registration form on the website or
mobile application. Please read Article 6.2 of this policy about updating of your personal
details.
The Company will not be able to verify the accuracy and correction of the data you provide
to us. By accepting your registration form, we will assume that your data is accurate and
correct, and all your consent are provided voluntarily, being fully aware of this Policy and
Rules.
1.2. Administration of your account
We process your data so that we can maintain and manage your account.

Account details:
Data categories Data provided when signing up to the Websites, account login details, account
activity, including technical browsing data (IP address, login and browsing
technical information)
Legal basis for
data processing
Your consent to create and use the account under the terms and conditions
provided for in the Rules
Term of data
processing
For the entire period when you are an account user. We can keep your consent
and proof of it for a longer period if necessary so that we can defend against any
claims, lawsuits or actions brought against us.
We consider your consent for using the accounts on the Websites to be received when you
perform the necessary actions for creating the account specified in the Rules and confirm the
registration.
1.3. Processing your purchase details.
Purchase data processing
By providing you our Services and offering various advantages – by concluding and
executing sales contracts, by making refunds (if you return the purchased item), by giving
discounts, etc. – In addition to your registration data, we also process the details of your
purchase transactions (hereinafter the purchase details).
Your purchase details are processed for the purpose of service administration:
Data
categories
Your name, surname, e-mail address, telephone number, delivery and residential
addresses, signature (if you accept the items yourself), date and time of purchase and
delivery, item names, quantities, purchase prices and discounts, payment method and
payment information
Legal basis for
data
processing
Your consent to use your account under the terms and conditions of the Rules
Term of data
processing
5 years from the date of the purchase transaction.
How do we use your purchase details?
We store your purchase details for 5 years from the date of the purchase transaction, and
upon expiry of this term we destroy them and/or reliably deconstruct, i.e., irrevocably
decouple them from your personal data and other personalized information.
1.4. Provision of offers and information
If you agree to receive offers and newsletters when filling in the registration form, we process
your personal data by providing you with such offers and information, such as general
newsletters, information about our and our partners’ offers, discounts, promotions, sales,
inviting you to participate in the campaigns, games and win prizes, listening to your feedback

about the services provided and products, etc. We provide offers and information in your
account, as well as in other ways that you choose: e.g. by mail, in SMS messages.
Personal data processed for the purpose of submitting offers and information:
Data categories Your name, email address and/or telephone number
Legal basis for
data processing
Your consent to receive offers and information
Term of data
processing
Until your consent to receive offers and news is valid. We can keep your consent
and proof of it for a longer period if necessary so that we can defend against any
claims, lawsuits or actions brought against us.
You can choose your preferred communication channels in the privacy settings of your
Website accounts. You can change these settings freely at any time. You may refuse to
receive offers and news at any time, at any time, to decline or change your preferred channels
(methods) for receiving notifications. Your refusal to receive offers and news will not prevent
you from using the Services.
1.5. Handling customer queries, complaints, requests and feedback
We will use your personal data to respond to your inquiries, complaints, requests, and
administer your feedback (hereinafter the Query).
Data processed when handling queries, complaints, requests for administration:
Data categories Identification and contact information you have specified: name, telephone
number, e-mail address, residential address, date of birth;
Content of your Query: the event you are contacting us for, its circumstances,
date, place, your request, claim or feedback, item, loyalty card number, other
information in the Query;
Other documents and/or data submitted with the Query: for example, purchase
receipt details; photos;
Phone call record if you contact our Customer Support Helpline.
Legal basis for data
processing
Our legal responsibility to investigate and respond to user Queries as well as our
legitimate interest in evaluating our customer feedback in order to improve the
quality of our business and services.
Term of data
processing
Up to 12 months
We use your data only in order to properly and objectively examine your Query, provide you
with the necessary information, answer your questions, and resolve your requests or
requirements. We can also analyze the data in the Query in order to improve the quality of
our activities and the services provided to you, taking into account your opinions and
suggestions.

1.6. Statistics, market research and consumer behaviour surveys
We constantly make every effort to ensure that our range of goods, promotions and discounts
are as close as possible to our customers’ needs.
Data processed for statistical, market, and behavioural studies of our customers:
Data categories Place of residence, purchase details (including date and time of purchase, item
names, quantities, total purchase price, amount of discounts)
Legal basis for data
processing
It is our legitimate interest to analyze the data and prepare reports for our
business in order to evaluate our activities and create value for you both as a
client and for the Company’s business.
Term of data
processing
5 years
We use automated data analysis in conducting surveys of statistics, market and customer
behaviour, and reporting on our business. During the analysis, we use non-personalized data
and do not process your name, contact details and other personal information. Data analysis
for the purpose of statistical, market, and customer behaviour testing enables us to make
important business decisions, such as the product range matching, customer pricing, etc.
Our data analysis activity do not have any legal or material implications for you.
2. How long do we process and store your data?
We process and store your Queries and the data related to it as long as we investigate the
Query, provide you with the answer and comply with the accepted decisions, as well as up to
12 (twelve) months after the Query has been resolved, but no less than:
– Queries by e-mail – 12 months;
– Appeals/complaints – 12 months;
– Call records on the hotline. – 14 days
– “Let’s Talk” function correspondence records – 14 days
– Instagram messages – 12 months;
– Facebook personal messages – 12 months;
If the Query is related to initiating a legal dispute or there is a likelihood of such a dispute, we
may retain your data longer, until the statutory limitation period for lodging a complaint or
action is due and/or the decision is finalized.
Upon the expiration of your data processing and retention period set forth in this Policy, we
will destroy your data or depersonalise you reliably and irrevocably as soon as possible,
within a reasonable and justifiable timeframe for such action.
3. From which sources do we collect your personal data?
We receive almost all of your personal data from you. You provide us your personal data
directly, for example by filling in registration forms, and purchasing details using the
Services.
We also receive your data directly from you when you submit a Query in any of the
following ways: by emailing us written request, by submitting as a written Query, by calling
our customer support line, etc.
If, in order to examine your Query with good quality and objectively, we need to collect

additional information or to investigate the relevant circumstances, we may associate the data
in your Query with the data we collect and (or) the data collected when investigating the
Query, for example, we can check the details of your purchase transactions, the history of
using your account, interview our employees, etc.
4. In which cases and to which third parties do we disclose your data?
We may transfer your data for processing to third parties who assist us in the execution and
administration of the Services, provide us with services related to the administration of
Customer Queries. These persons may include database software vendors, database
administrators, data centres, hosting and cloud service providers, direct marketing service
providers, market research or business intelligence service providers, providers of careers
service, etc. In each case, we provide to the data processor only as much data as is absolutely
necessary to complete a specific order or provide a specific service. Our recruited data
processors can process your personal data only according to our instructions and cannot use
them for other purposes or transfer to others without our consent. In addition, they must
ensure the security of your data in accordance with applicable law and written agreements
with us.
If, in the provision of the Services, we grant the right to use our partner services (for example,
through partners’ loyalty programs), some of your data will also be made available to our
partner, but only for the purpose of providing such services or other terms of co-operation.
If the Event description described in the Query can be recognised as insured, we will transfer
your Query and data to the insurance company (ies) where we insure our civil liability,
property or which provides us with a different insurance coverage related to the event named
in your Query. Insurance companies act as independent data controllers and process your data
in accordance with the terms and conditions established by the insurance company.
Data may also be provided to competent authorities or law enforcement agencies such as the
police or the supervisory authorities, but only upon request and only when required by
applicable law or in the cases and procedures provided by law, in order to safeguard our
rights, the safety of our buyers, employees and resources, and to bring forward, present and
defend legal requirements.
If we use the website analysis service (such as Google Analytics) to determine how you use
the information provided on the Website, we may exchange your depersonalized data with
third parties who rely on this information to evaluate how the Website is used, to prepare
reports the website operators about the Website functioning, and to provide other services
related to the use of the website. For more information, see annex1
– Cookie policy.
5. In which territories and jurisdictions do we process your personal data?
We process your personal data only in the territory of the European Union. We do not
transfer your personal data to third countries.
6. What of your rights are guaranteed by the data protection legislation and how can
you use it?
Data protection legislation gives you many rights that you can freely use, and we need to
provide you with that opportunity. We provide information about your specific rights and
how they are implemented are presented in this Policy below, please read it carefully.

6.1. The right to access our personal data processed by us
You are entitled to receive our confirmation as to whether we process your personal data, as
well as the right to access our personal data and information about the objectives of
processing your data, the categories of data being processed, categories of recipients of data,
the period of data processing, sources of data and the consequences for you.
We provide the majority of this information to you in this Policy and we believe that it is
useful to you.
If you are a user of website accounts, you can access your personal data at any time from
your account (for example: check the relevant personal information, the concerns you have
provided), receive invoices issued to you for the last 12 months.
If the information provided in this Policy, the Website accounts is not sufficient to you, or if
you would like to receive a transaction history for more than 12 months, you can always
contact us by email info@sinfulcars.com.
6.2. The right to correct personal data
If the information you submit it to us in the registration form has changed, or if you believe
our information about you is inaccurate or incorrect, you have the right to request that
information to be corrected, revised or changed.
You can make adjustments to your data on the Website accounts. You can also contact us by
e-mail to info@sinfulcars.com and request that your information is corrected or revised by us.
6.3. Right to withdraw your consent
In cases where we process your data on the basis of your consent, you are entitled to
withdraw your consent at any time and the processing of your data based on your consent will
be terminated. In certain cases, this may mean that we will no longer be able to continue to
use our Services.
For example, you may at any time withdraw your consent to receive offers and news.
Withdrawal of these consents will not prevent you from continuing to use the Services, but
this will mean that you will not be aware of the Company’s discounts, promotions, new
arrivals etc.
You can edit (cancel or resubmit) your consents by submitting an appropriately updated
registration form, by changing the consent settings in your account, or by contacting us by
email info@sinfulcars.com.
Upon expiration, withdrawal or cancellation of your consent, we will destroy the data
processed with your consent, and in the cases specified in the Policy we will depersonalise
them reliably and irrevocably.
In any event, we may retain your consent and proof of it for a longer period, if necessary, so
that we can defend against claims, lawsuits or actions brought against us.
6.4. Right to file a complaint
If you believe that we process your data in violation of the requirements of the data protection
laws, we will always ask you to contact us directly first. We believe that by benevolent
efforts, we will be able to dispel all your doubts, satisfy requests and correct our mistakes, if
any.
If you are not satisfied with our proposed solution to the problem or, in your opinion, we do
not take action as required by your request, you will have the right to file a complaint to the

 

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