We use cookies to provide the best site experience.
Ok, don't show again
Close
We use cookies to provide the best site experience.
Close

Privacy Policy of wholepacks.com

This Application collects some Personal Data from its Users.
Owner and Data Controller

WHOLEPACKS GROUP
BELARUS
Kazinca str, 11A, office B-715
Owner contact email: julia@wholepacks.com

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies, Usage Data, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), geography/region, number of sessions, session duration, Application opens, Application updates, first launches, operating systems, Data communicated while using the service, first name, last name, phone number, VAT Number, address, country, state, email address, ZIP/Postal code, various types of Data and Tax ID.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data


Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:
  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing ("opt-out"), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the Owner's legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Analytics, Backup saving and management, Beta Testing, Contacting the User, Data transfer outside the EU, Interaction with online survey platforms, Remarketing and behavioral targeting, SPAM protection and Tag Management.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Analytics
  • The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Analystics collected directly
  • This Application uses an internal analytics system that does not involve third parties.
  • Personal Data collected: Cookies and Usage Data.
Business Contact (Italiaonline S.p.A.)
  • Business Contact – аналитический сервис, предоставляемый компанией Italiaonline S.p.A.
  • Personal Data collected: Cookies and Usage Data.
  • Place of processing: Italy – Privacy Policy.
Alexa Metrics(Alexa Internet, Inc.)
  • Alexa Metrics is an analytics service provided by Alexa Internet, Inc.
  • Personal Data collected: Cookies and Usage Data.
  • Place of processing: United States – Privacy PolicyOpt Out.
Adobe Analytics (Adobe Systems Incorporated)
  • Adobe Analytics is an analytics service provided by Adobe Systems, Inc.
  • Personal Data collected: Cookies and Usage Data.
  • Place of processing: United States – Privacy PolicyOpt Out. Privacy Shield participant.
Google Analytics (Google LLC)
  • Google Analytics is a web analysis service provided by Google LLC ("Google"). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
  • Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
  • Personal Data collected: Cookies and Usage Data.
  • Place of processing: United States – Privacy PolicyOpt Out. Privacy Shield participant.
Google Analytics for Firebase (Google LLC)
  • Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google LLC.
In order to understand Google's use of Data, consult Google partner policy.
  • Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.
  • This Application uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service.
  • Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.
  • Personal Data collected: Application opens, Application updates, Cookies, first launches, geography/region, number of sessions, operating systems, session duration, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.
  • Place of processing: United States – Privacy Policy. Privacy Shield participant.
AppFireworks (App Fireworks Ltd.)
  • AppFireworks is an analytics service provided by App Fireworks Pty Ltd.
  • Personal Data collected: Cookies and Usage Data.
  • Place of processing: Australia – Privacy Policy.
Google Ads conversion tracking (Google LLC)
  • Google Ads conversion tracking is an analytics service provided by Google LLC that connects data from the Google Ads advertising network with actions performed on this Application.
  • Personal Data collected: Cookies and Usage Data.
  • Place of processing: United States – Privacy Policy. Privacy Shield participant.
Google Analytics with anonymized IP (Google LLC)
  • Google Analytics is a web analysis service provided by Google LLC ("Google"). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
  • Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
  • This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.
  • Personal Data collected: Cookies and Usage Data.
  • Place of processing: United States – Privacy PolicyOpt Out. Privacy Shield participant.
Web-stat live (Web Tracking Services, LLC)
  • Web-Stat live is an analytics service provided by Web Tracking Services, LLC.
  • Personal Data collected: Cookies and Usage Data.
  • Place of processing: United States – Privacy Policy.
Backup saving and management
  • This type of service allows the Owner to save and manage backups of this Application on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to this Application.
Backup on Google Drive (Google LLC)
  • Google Drive is a service to save and manage backups provided by Google LLC.
  • Personal Data collected: various types of Data as specified in the privacy policy of the service.
  • Place of processing: United States – Privacy Policy. Privacy Shield participant.
Beta testing
  • This type of service makes it possible to manage User access to this Application, or parts of it, for the purpose of testing a certain feature or the entire Application.
  • The service provider may automatically collect data related to crashes and statistics related to the User's use of this Application in a personally identifiable form.
Beta by Crashlytics (Google LLC)
  • Beta by Crashlytics is a beta testing service provided by Google LLC.
  • Personal Data collected: Cookies and Data communicated while using the service.
  • Place of processing: United States – Privacy Policy.
Contacting the UserContact form (this Application)
  • By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form's header.
  • Personal Data collected: address, country, email address, first name, last name, phone number, state, Tax ID, various types of Data, VAT Number and ZIP/Postal code.
Phone contact (this Application)
  • Users that provided their phone number might be contacted for commercial or promotional purposes related to this Application, as well as for fulfilling support requests.
  • Personal Data collected: phone number.
Data transfer outside the EU
  • The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
  • Users can inquire with the Owner to learn which legal basis applies to which specific service.
Data transfer abroad based on consent (tis Application)
  • If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
  • In such cases, the Owner shall inform Users appropriately and collect their explicit consent via this Application.
  • Personal Data collected: various types of Data.
Data transfer abroad based on standard contractual clauses (this Application)
  • If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to "standard contractual clauses" provided by the European Commission.
  • This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.
  • Personal Data collected: various types of Data.
Interaction with online survey platforms
  • This type of service allows Users to interact with third-party online survey platforms directly from the pages of this Application.
  • If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.
Customerly Survey Widget (Customerly Ltd.)
  • The Customerly Survey Widget is a service for interacting with the Customerly online survey platform provided by Customerly Ltd.
  • Personal Data collected: Cookies, Data communicated while using the service and Usage Data.
  • Place of processing: Ireland – Privacy Policy.
Remarketing and behavioral targeting
  • This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use of this Application by the User.
  • This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.
  • Some services offer a remarketing option based on email address lists.
  • In addition to any opt-out offered by any of the services below, the User may opt out of a third-party service's use of cookies by visiting the Network Advertising Initiative opt-out page.
Salesforce DMP (salesforce.com, inc.)
  • Salesforce DMP is a remarketing and behavioral targeting service provided by salesforce.com, inc.
  • Salesforce DMP makes use of tracking technologies to monitor User behavior. This Data is then used to personalize the User's experience and to provide targeted advertising. Salesforce DMP may also connect the collected Data with other networks, including advertising networks, and enable these parties to track and target the User. The Owner, unless otherwise specified in this document, has no direct relationship with the third parties that Salesforce DMP may be including.
  • Personal Data collected: Cookies and Usage Data.
  • Place of processing: United States – Privacy PolicyOpt Out. Privacy Shield participant.
Google Ad Manager Audience Extension (Google LLC)
  • Google Ad Manager Audience Extension is a remarketing and behavioral targeting service provided by Google LLC that tracks the visitors of this Application and allows selected advertising partners to display targeted ads across the web to them.
  • Personal Data collected: Cookies and Usage Data.
  • Place of processing: United States – Privacy PolicyOpt Out. Privacy Shield participant.
SPAM protection
  • This type of service analyzes the traffic of this Application, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.
Google reCAPTCHA (Google LLC)
  • Google reCAPTCHA is a SPAM protection service provided by Google LLC.
  • The use of reCAPTCHA is subject to the Google privacy policy and terms of use.
  • Personal Data collected: Cookies and Usage Data.
  • Place of processing: United States – Privacy Policy. Privacy Shield participant.
Tag Management
  • This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralized fashion.
  • This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager (Google LLC)
  • Google Tag Manager is a tag management service provided by Google LLC.
  • Personal Data collected: Cookies and Usage Data.
  • Place of processing: United States – Privacy Policy. Privacy Shield participant.
Further information about Personal Data
WHOLEPACKS Analysis and predictions based on the User's Data ("profiling")
  • The Owner may use the Personal and Usage Data collected through this Application to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
  • User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more, about the profiling activities performed, Users can check the relevant sections of this document.
  • The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.
Personal Data collected through sources other than the User
  • The Owner of this Application may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
  • Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.
Unique Device identification
  • This Application may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.
The Service is not directed to children under the age 13
  • Users declare themselves to be adult according to their applicable legislation. Minors may use this Application only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use this Application.
Privacy Shield participation: data transfers from the EU and Switzerland to the United States
  • The Owner participates in and complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union and Switzerland to the United States. The policies and rights outlined below are therefore equally and explicitly applicable to Users from Switzerland, except if stated otherwise. The Owner has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.
  • If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view the Owner's certification, please visit https://www.privacyshield.gov/ (or find the direct link to the certification list of Privacy Shield participants maintained by the Department of Commercehttps://www.privacyshield.gov/list).
What does it mean for the European User?
  • The Owner is responsible for all processing of Personal Data it receives under the Privacy Shield Framework from European Union individuals and commits to subject the processed Personal Data to the Privacy Shield Principles.
  • This, most importantly, includes the right of individuals to access their personal data processed by the Owner.
  • The Owner also complies with the Privacy Shield Principles for all onward transfers of Personal Data from the EU, which means that it remains liable in cases of onward transfers to third parties.
  • With respect to Personal Data received or transferred pursuant to the Privacy Shield Framework, the Owner is subject to the investigatory and regulatory enforcement powers of the FTC, if not stated otherwise in this privacy policy.
  • The Owner is further required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Dispute resolution under the Privacy Shield
  • In compliance with the Privacy Shield Principles, the Owner commits to resolve complaints about its collection or use of the User's Personal Data. European Union individuals with inquiries or complaints regarding this Privacy Shield policy should first contact the Owner at the contact details supplied at the beginning of this document referring to "Privacy Shield" and expect the complaint to be dealt with within 45 days.
  • In case of failure by the Owner to provide a satisfactory or timely response, the User has the option of involving an independent dispute resolution body, free of charge.
  • In this regard, the Owner has agreed to cooperate with the panel established by the EU data protection authorities (DPAs) and comply with the advice given by the panel with regard to data transferred from the EU. The User may therefore contact the Owner at the email address provided at the beginning of this document in order to be directed to the relevant DPA contacts.
  • Under certain conditions – available for the User in full on the Privacy Shield website (https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint) – the User may invoke binding arbitration when other dispute resolution procedures have been exhausted.
The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Additional information about Data collection and processing

Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How "Do Not Track" requests are handled
This Application does not support "Do Not Track" requests.
To determine whether any of the third-party services it uses honor the "Do Not Track" requests, please read their privacy policies.

Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.


Should the changes affect processing activities performed on the basis of the User's consent, the Owner shall collect new consent from the User, where required.


Definitions and legal references

Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject
The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application The means by which the Personal Data of the User is collected and processed.

Service
The service provided by this Application as described in the relative terms (if available) and on this site/application.

European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookies
Small sets of data stored in the User's device.


Legal information
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
This privacy policy relates solely to this Application, if not stated otherwise within this document.
Latest update: October 09, 2018
iubenda hosts this content and only collects the Personal Data strictly necessary for it to be provided

Show the simplified Privacy Policy