ENGINO-NET LIMITED operates in the field of development, manufacturing and sale of innovative modular building toys to serve the retail and educational sector.
We are committed to safeguarding your privacy and handling your data in an open and transparent manner. Looking after the personal data you share with us is hugely important to us.
We would like to reassure you that your privacy is our first priority, and that your data is safe and secure.
We therefore want to be clear about how we use it, in order to offer you a better and more personalized shopping experience.
WHAT THIS POLICY COVERS
sets out the types of personal data that we collect;
explains how and why we collect and use your personal data;
explains when and why we share personal data within Engino® ;
is clear about the rights and choices you have when it comes to your personal data;
informs of who has access to this type of information, and
Informs of the retention period
We offer a wide range of products and services. This Policy applies to you if you use our services, whether you’re ordering from us over the phone, online, at any of our stores or retail locations, or if you’re a member of the Engino Club.
This Policy also applies if you contact us or we contact you about our products and services.
WHAT TYPES OF PERSONAL DATA WE COLLECT
The information we hold come essentially from the information you personally provide us when you register to become an Engino Club member. Upon your registration, we ask for your personal data (such as your first name, last name, the city where you live, your email address, and your phone number), hence those data are provided by you throughout your registration to the platform. Most of this information is provided and generated when a visitor creates his or her account and is available and can be updated by him or her in the account settings section.
Information are also collected from other sources than through the registration process such as competitions, promotions, surveys or questionnaires about our services, or when you sign up for our newsletter.
Anytime you contact us about our services either by phone, email or post, or when you communicate with us through social media, we may also collect the personal data you provide about yourself.
Sometimes we may collect details from emails and other digital communication we send to you that you open, including any links in them that you click on.
If you sign up via our websites or mobile applications to place an order with us, we will request your account login details (personal information), such as your email, password, last name, first name, mobile number, and billing and shipping addresses.
Transaction/ Purchasing information: If you place an order with us, we will also ask for a delivery address and your payment details. We may ask you for this information through our websites or mobile applications, or via one of our telephone operators, or we may collect this information through your email or from other communications with us. Also, when you use your Engino Club Membership to shop with us, or any gift vouchers or coupons, we will collect transaction information.
We may also ask you for other optional information, such as what sort of device you’re using (i.e. desktop, mobile phone or tablet), how you heard about our website and what sort of subjects interest you. If you choose to give us this information, we will use it to help us provide you with the best possible service, personalized to your needs and preferences. Although we do not make it compulsory for you to give us all the information we ask for, the more information you volunteer (and the more accurate it is), the better we can tailor our services to your needs.
We may also use personal data from other sources, such as specialist companies that supply information. This personal data helps us to manage your Engino Club Membership account, review and improve the accuracy of the data we hold, and improve and measure the effectiveness of our marketing communications, including online advertising.
We may automatically collect non-personal information about you, such as the type of internet browsers you use or the site from which you were linked to our websites. This information cannot identify you and it is only used to assist us in providing effective service on our websites.
HOW AND WHY WE USE PERSONAL DATA
We collect and use your information for its core business and operational activities to provide you with the best quality of services and experiences. We use personal data to make our products and services available to you. For the reason we manage the accounts you hold with us, including your Engino Club Membership account.
Personal data assists us in processing your orders. We need to process your personal data so that we can manage your customer account, provide you with the goods and services you want to buy, and help you with your order queries.
Processing of personal data also helps us develop and improve our product range, services, stores, information technology systems, know-how and the way we communicate with you. This allows us to serve you better.
It is important for us to monitor how our services are used in order to detect and prevent fraud, other crimes and the misuse of services. This reassures us that you can safely use our services.
We use personal data to assist us in personalizing your shopping experience with us. We do this by using your online browsing experience, as well as your in-store and online purchases, which help us to better understand you as a customer and to provide you with personalized offers and services.
Online advertising may be displayed across our websites. This will help us measure the effectiveness of our marketing communications and provide you with more relevant marketing communications (via email, post, SMS or online advertising) related to our products and services.
We do this because we want to provide you with marketing communications, including online advertising, that are relevant to your interests. To tailor our marketing campaigns, we also measure your responses to marketing communications related to the products and services we offer, which also means we can offer products and services that better meet your needs as a customer.
We may contact you about our products and services, either by phone, email or post, or by responding to social media posts that you have directed at us. We do this because we want to serve you better. We use your personal data to provide clarification or assistance in response to your communications.
We may also contact you in order to manage the promotions and competitions you take part in or to invite you to take part in and manage customer surveys, questionnaires and other market research activities carried out by our Marketing Department or by other organizations on our behalf. We do this in order to improve our services.
However, if we contact you, you do not have to take part in any of these activities. If you tell us that you do not want us to contact you for marketing research, we will respect this choice. This will not affect your ability to use our Services or your Engino Club Membership.
Your personal data will be processed provided that a specific consent is obtained for processing those data (other than for the reasons set out hereinabove). The lawfulness of such processing is based on that consent. You have the right to revoke consent at any time. However, any processing of personal data prior to the receipt of your revocation will not be affected.
When and why we share personal data within Engino® and with other organizations
We would like to let you know that we work with carefully selected Service Providers that carry out certain functions on our behalf. These include, for example, companies that help us with technology services, storing and combining data, processing payments and delivering orders. We would like to assure you that we only share personal data that enable our Service Providers to provide their services.
Some of the Service Providers we work with operate online media channels, and they place relevant online advertising for our products and services on those online media channels on our behalf. For example, you may see an advert for our products and services as you use particular social media sites.
We may share personal data with other organizations, if the law or a public authority says we must share personal data, or if we need to share personal data in order to establish, exercise or defend our legal rights.
Other than the disclosures referred to in this policy, we will not disclose any personal information without your consent, unless we are legally entitled or obliged to do so (for example, if required to do so by court order or for the purposes of prevention of fraud or any other crime).
How we protect your personal data
At Engino® we are committed to respecting, protecting and maintaining your privacy, and have many measures in place to do so.
For example, we use computer safeguards such as firewalls and data encryption. We also enforce physical access controls to our buildings and files to keep this data safe. We only authorize access to employees who need it to carry out their job responsibilities.
As part of our policies, we enforce physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal data. We may occasionally ask for proof of identity before we share your personal data with you.
If you select the option to allow us to store your card details, then we will do so using the Payment Gateway Token System. If you select repeat purchase product, then we will automatically store your card details via the Payment Gateway Token System. The Token System is a safe way of keeping card details without actually storing them. Payment Gateway stores and converts a customer's sensitive payment information into a secure token or "alias". This token is then used by our websites or mobile applications to process future transactions as and when required, without asking for your card details each time. When confirming an order, we will reveal only the last four digits of your credit card number.
The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by companies operating outside the EEA who work for us or for one of our Service Providers. We would like to reassure you that we will put in place appropriate protection measures to make sure that your personal data remains adequately protected and is treated in line with this Policy.
You should be aware that the internet is an insecure environment. Whilst we take appropriate technical and organizational measures to safeguard your personal data, please note that we cannot guarantee the security of any personal data that you transfer over the internet to us. However, we will continue to update these measures, as appropriate, when new technology becomes available.
Cookies and other similar technologies
Some cookies are necessary so you should not disable these if you want to be able to use all the features of our websites and mobile applications. You can disable other cookies, but this may affect your shopping experience. Also, you can choose not to accept our cookies, but certain functions of our websites may not work correctly or at all if you set your browser not to accept cookies.
When it comes to cookies, you have many choices. You can use your browser settings to accept or reject new cookies and to delete existing cookies. You can also set your browser to notify you each time new cookies are placed on your computer or other device.
Cookies allow us to improve the way our websites and mobile applications work so that we can personalize your experience and allow you to use many of their useful features.
In addition, cookies can help us to understand how our websites and mobile applications are being used; for example, by telling us if you get an error message as you browse. The data that cookies collect is mostly aggregated and anonymous.
When you visit our websites, these cookies automatically log your IP address (the unique address which identifies your computer on the internet) which is automatically recognized by our web server. We use IP addresses to help us administer our websites and to collect broad demographic information for aggregate use. Your IP address is also logged when you make a purchase as a fraud prevention measure required by our payment gateway.
In this way, we can measure the effectiveness of our marketing communications, including online advertising campaigns. For example, cookies will tell us if you have opened a marketing email that we have sent you and the number of times you are shown an advert. Cookies can also tell us if you have seen a specific advert and how long it has been since you have seen it.
It is very important for us to protect children's privacy. We may
collect personal data in relation to children, provided that we have first obtained their parents’ or legal guardian’s consent, or if otherwise permitted by law. We do not provide any Engino Club Membership services to children, but we may allow children, with their parents’ or legal guardian’s consent, to use our websites, mobile applications and social media sites. For the purposes of this privacy statement, “children” are individuals who are under the age of eighteen (18).
How long we keep your personal information
We will keep your personal data for as long as you would like us to and for as long as you are a customer of our shops. Once our business relationship with you has ended, we may keep your data for up to 1 (1) year in accordance with the directive of the Data Protection Commissioner..
You will be reminded 2 weeks before the deletion of your data and then the data will be deleted automatically.
We may keep your data for longer than 1 year if we cannot delete it for legal, regulatory or technical reasons.
Engino Net Ltd (“Engino”) has taken appropriate measures to provide any information relating to your rights as well as the exercise of these rights. Under the General Data Protection Regulation (EU) 2018/679 Chapter III, which is applicable as of 25 May 2018, you have the following rights:
Transparent information, communication and modalities for the exercise of your rights
You have the right to be provided with your data freely and in an intelligible and easily accessible form. Following your request, Engino shall provide information without undue delay and in any event within 3rd month of receipt of the request. That period may be extended by …….. further months where necessary, taking into account the complexity and number of requests. In that case the Engino will inform you for the reasons of the delay.
Right of access
You have the right to request and receive a copy of your personal data undergoing processing. This enables you to, for example, receive a copy of the personal data we hold about you and to check that we are processing it lawfully. In order to receive such a copy you can contact us at firstname.lastname@example.org. However, for any further copies requested, Engino may charge you a reasonable fee that is based on administrative costs.
Information to be provided where personal data are collected from the data subject
You have the right to know the contact details of the agent who collects your data, the purposes of the processing for which the personal data are intended, the legal basis for the processing, the recipients or categories of recipients of the personal data and where applicable the fact that the controller intends to transfer personal data to a third country.
Right to rectification
You have the right to obtain from Engino within reasonable time the rectification of inaccurate personal data concerning you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
5.Right to erasure (‘right to be forgotten’)
There is a right to ask for the erasure of your personal data and no longer processed where the personal data are no longer necessary in relation to the purposes for which they are controlled or otherwise processed.
Hence, in the cases where Engino retains and process personal data in accordance with the provisions of Article 6(1)(c) of the GDPR, Engino may object to such a request and may keep the relevant personal data that are required in order for Engino to comply with its legal obligations.
Right to object
We ensure that Engino has in place a procedure where you have the right to object to the processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. If you lodge an objection, we will no longer process your personal data, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms.
You also have the right to object when we are processing your personal data, for marketing purposes. If you object to data processing for marketing purposes, then we shall stop processing your personal data for such purposes.
Right to restriction of processing
We ensure that the Engino has in place a procedure where you have the right to restrict the processing of your personal data. This enables you to ask us to restrict the processing of your personal data, i.e. use it only for certain things, if:
it is not accurate,
it has been used unlawfully, but you do not wish for us to delete it,
it is not relevant anymore, but you want us to keep it for use in possible legal claims,
or if you have already asked us to stop using your personal data but you are waiting for us to confirm if we have legitimate grounds to use your data.
Nonetheless, for those personal data that are necessary for compliance with a legal obligation, Engino may object to the restriction.
Right to data portability
You have the right to request to receive a copy of your personal data in a format that is structured and commonly used, and to transmit such data to other organizations. You also have the right to have your personal data transmitted directly by us to other organizations you will name (known as the “right to data portability”).
Right to withdraw your consent
You have the right to withdraw your consent regarding the processing of your personal data at any time. Note that any withdrawal of consent shall not affect the lawfulness of processing based on consent before it was withdrawn or revoked by you. You have the right to withdraw your consent given to us, opt out, unsubscribe or change preferences via a link in the footer of all non-transactional email messages. These options are made available when you sign up for our email lists and in email messages delivered from us.
If, at any time, you believe that you have received an unsolicited commercial email on behalf of somebody else, you may report it to us at email@example.com.
It is very important to us that we provide you with the highest level of service. In order to do this better, from time to time we may contact you using one of the contact methods you have provided, with details of our newsletters, surveys, products and services which we think may be of interest to you. If at any time you do not wish to receive these communications, simply click on the ‘unsubscribe’ link at the bottom of the email. Please note that active customers will continue to receive order and account communications from us.
We aim to keep our information about you as accurate as possible. If you would like to review or change the details you have supplied us with, or you would like to remove your published submission from the site, you may do so at any.
Right to lodge a complaint
If you have exercised any or all of your data protection rights and still feel that your concerns about how we use your personal data have not been adequately addressed by us, you have the right to send a complaint to the office of the Personal Data protection Commissioner.
Changes to this privacy statement
We may modify or amend this privacy statement from time to time. We will notify you appropriately when we make changes to this privacy statement and we will amend the revision date at the top of this page. We do, however, encourage you to review this statement periodically so as to always be informed about how we are processing and protecting your personal information.
To exercise any of your rights, or if you have any other questions about our use of your personal data, please contact us by sending an email to firstname.lastname@example.org.
You can also contact our Data Protection Officer at Engino®.
Your concerns are very important to us and we endeavor to address all of your requests promptly.
The General Data Protection Regulation (EU) 2016/679 shall apply from 25 May 2018 on. Until then, the Processing of Personal Data (Protection of Individuals) Laws 2001-2012 remain in force.