Privacy Statement

We are committed to safeguarding the privacy of our website visitors.
It is important to us that you understand how we will treat your personal data, i.e. any information that relates to you and warrants protection under the Regulation (EU) 2016/679 (GDPR), and that you are aware of your statutory rights.


(1) What information do we collect?

We may collect, store and use the following kinds of personal data:

(a) Information about your visits to and use of this website, as explained below in section (2);

(b) Information about any transactions carried out between you and us, including information relating to any purchases you make of our goods or services, as explained below in section (3);

(c) Information that you provide to us for the purpose of registering with us and/or subscribing to our website services and/or email notifications, as explained below in section (4).

(2) Information about website visits and the use of cookies

We may collect information about your computer and your visits to this website such as your IP address, geographical location, browser type, referral source, length of visit and number of page views. We may use this information to pursue our legitimate interests, namely in the administration of this website, to improve the website’s usability, and to improve your browsing experience by personalizing the website. We may also use such information for marketing purposes, as further specified in section (5).

We use cookies on this website. A cookie is a text file sent by a web server to a web browser, and stored by the browser. The text file is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.

We may send a cookie which may be stored on by your browser on your computer’s hard drive. We may use the information we obtain from the cookie in the administration of this website, to improve the website’s usability and for marketing purposes. We may also use that information to recognize your computer when you visit our website, and to personalize our website for you.

It is easy to refuse or limit the use of cookies through your browser settings at any point in time (for example, in Internet Explorer you can refuse all cookie by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector.). Please note that this might affect certain functionalities of this website.

(3) Information about transactions

We store information about any transaction concluded between you and us, including invoicing details as required under local legislation. We use this information in order to comply with laws governing the execution of such transactions, including amongst others taxation requirements. We also process such information to perform our obligations and pursue our rights under the contract entered into by you and us, including in the context of any legal proceedings if necessary.

Such information is also collected and treated at the stage prior to concluding any contract as a follow-up to you placing an order or making any other relevant inquiry.

Furthermore, we use this information in the context of our legitimate interests, namely to carry out actions in view of our direct marketing purposes, as further specified in section (5).

(4) Website subscription information and newsletters

We collect and use information you provide us with, after having declared your consent, when you sign up on our website services to ensure user authentication and enable our website to perform the functions you choose.

We also gather and process information when you subscribe to our newsletter lists.

Furthermore, we use this information in the context of our legitimate interests, namely to carry out actions in view of our direct marketing purposes, as further specified in section (5).

(5) Direct marketing in more detail

In the context of our direct marketing purposes, we may use your personal information, wherever this is stipulated in this policy, to:

(a) Send to you marketing communications relating to our business which we think may be of interest to you by post or, where you have specifically agreed to this, by email or similar technology;

(6) Recipients of personal data

Without prejudice to any disclosure of information made compulsory by competent authorities and only to the extent such disclosure is required by law, we may disclose information about you:

(a) Where necessary in the context of the purposes stipulated in this policy, such as to authorized employees among our staff; or contractors, whether legal entities or individuals, acting on our behalf as processors under the GDPR; or companies belonging to the KOEPON HOLDING acting as joint controllers or on our behalf as processors under the GDPR; and

(b) To the purchaser or seller (or prospective purchaser or seller) of any business or asset which we are (or are contemplating) selling or purchasing.

(7) International data transfers

Information that we collect may be stored and processed in and transferred between any of the countries in which we or KOEPON HOLDING operate in order to enable us to use the information in accordance with this privacy policy.

We note that the GDPR establishes the free flow of personal data throughout the European Union. To the extent personal data is transferred to third countries we store our data on Microsoft Azure and Office 365 data centers that may be outside the EU. However, we ensure our data access polices are inline with GDPR no matter where the data is stored.

(8) Data retention

Without prejudice to your rights explained in section (9), we will keep your personal information for an appropriate period considering the nature of such data and the purposes for which they are processed.

Information about your visits to and use of this website shall be kept within our Google Anayltics Data for up to 24 months, after which time has passed we will automatically remove any customer data collected.

Information pertinent to transactions between you and us shall be stored throughout the lifecycle of the transactions concerned and for as long as is necessary for the pursuit of legal claims or required by local law, including amongst others tax legislation.

Information from your subscription to our website and newsletter lists shall be kept within our Email Marketing Software ( DOTMAILER ). We may contact you on a regular basis to seek for the renewal of your approval of us keeping such information.

(9) Your rights under the GDPR

As a data subject, i.e. an identified or identifiable natural person, you are entitled to exercise any of the following rights with regard to your personal data processed by us, subject to the conditions provided for by law:

(a) Right of access to your personal data;

(b) Right to rectification and erasure of your personal data;

(c) Right to restriction of processing concerning your personal data;

(d) Right to object to processing, including, amongst others, profiling;

(e) Right to data portability;

(f) Right to withdraw your consent, when it comes to processing of data on such basis (please note however that withdrawal of your consent would not affect the lawfulness of processing that would have taken place before you notify us of your withdrawal); and

(g) Right to lodge a complaint with a supervisory authority.

You may exercise your rights by contacting us in any suitable way, such as by phone or post, using the contact details referred to in section (12). However, we strongly encourage you to do so by email: privacy@koepon.com in order to enable us to deal with your request swiftly.

(9) Security of your personal data

We shall implement appropriate technical and organizational measures to ensure the protection of your privacy and a level of security appropriate to the risks entailed in any processing operation. We will take reasonable precautions to prevent the loss, misuse or alteration of your personal information.

However, we note that data transmission over the internet is inherently insecure, and we shall have no liability for events for which we are not responsible, as provided for in the GDPR.

(10) Policy amendments

We may update this privacy policy from time-to-time by posting a new version on our website.

(11) Third party websites

The website contains links to other websites. We are not responsible for the privacy policies (or content) of third party websites.

(12) Our identity and contact details

We act as controllers under the GDPR. Should you have any concern about your privacy, or in case you want to exercise your rights as a data subject, please use the following contact details:

Koepon Holding, Privacy team, privacy@koepon.com

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