PRIVACY POLICY

SIA "Paul Mason Properties" (hereinafter “we”) respects your privacy and is committed to protect it through compliance with this privacy policy (hereinafter the “Privacy policy”). In this Privacy policy we will inform you about our processing of your personal data. We commit ourselves to be transparent with you by providing clear information about what personal data we process, the purpose of processing, the retention period of the personal data as well as the legal basis for the processing and other information that we are required to provide pursuant to applicable legislation. 

Topics:
1.    What personal data do we process and why?
1.1. IKEA account
1.2. IKEA FAMILY
1.3. Statistical analysis
1.4. Direct marketing  
2.    How do we collect information about you?
3.    How long do we keep your personal data?
4.    To whom personal data are disclosed?
5.    Protection of personal data
6.    Your rights 
7.    Changes to our privacy policy
8.    Contact information

1.    What personal data do we process and why?
Having created an IKEA account on our website, when you join IKEA FAMILY program or agree to receive direct marketing in our web-page, you provide personal data that we will process. The categories of personal data that we process about you, purposes and legal basis for the processing are the following:

1.1    IKEA account (registration and administration)
Categories of personal data Legal basis for the processing
E-mail, name, surname, phone, password (encrypted), lists of goods (name of the list, date of creation, goods, number of goods, amount), a list of favourite goods (goods, amount), action within the IKEA account, including technical browsing data (log-in information, for instance, the last time you logged in, edited data), details of the IKEA FAMILY card specified in Paragraph 1.2 (if you registered IKEA FAMILY card), information which you provide when ordering direct marketing as specified in Paragraph 1.2 or 1.4 (if you have ordered/subscribed) Your consent which is deemed given when you activate your account

You can create your IKEA account on our website. In such case we will process your data so as to provide you with the opportunity to create an account to be able to use it for taking advantage of services offered to registered users for the purpose of administration and maintenance, also to recognise you when you  lodge inquiries, to notify you of any changes in the terms and conditions of the account (Privacy policy, changes in terms and conditions, etc.) or to contact you in emergencies (in case of any problems with regard to the account, in case some items are lost, etc.). We also process your data for the statistical purposes as described in Paragraph 1.3.
In your IKEA  account, you can see what your personal data is processed by us, including IKEA FAMILY details (if you have registered your IKEA FAMILY card), edit information about yourself, change the settings with regard to direct marketing, participation in games and/or contests/competitions, save, download lists of goods as well as lists of favourite goods.
To create an IKEA account you have to agree with the terms and conditions and to provide your personal data. If you disagree with the terms and conditions and refuse to provide your personal data, you will be unable to create an account.
By registering IKEA account you approve that you are at least 18 years of age and your personal data are accurate and correct. In cases of inaccuracies you should immediately correct them. 

1.2    IKEA FAMILY 
Management of IKEA FAMILY membership
Categories of personal data Legal basis for the processing
Name, surname, date of birth, e-mail, phone number, country, IKEA FAMILY card number, purchase history using IKEA FAMILY card (date and time of a purchase, receipt number, names of goods, quantities, prices, total amount of purchases); type of IKEA FAMILY card (physical or virtual)   Performance of a contract with you
   
If you would like to become a member of IKEA FAMILY, receive the IKEA FAMILY card and its advantages, and agree with IKEA FAMILY terms and conditions, then we collect certain information about you. We use this data in order to issue your personal IKEA FAMILY card, identify you in case of queries, to manage of the activities necessary to allow for you to use discounts and other benefits with IKEA FAMILY card, to communicate by e-mail about your membership in IKEA FAMILY (e.g. changes of privacy policy, terms and conditions and etc.) and communicate by phone number in urgent cases (e.g. issues in transactions, if you lost things ant etc.). Also, in order to provide for you important IKEA FAMILY information based on country we are collecting your country.  We also process your personal data for the statistical purposes as described in Paragraph 1.3.
If you would like to join IKEA FAMILY program you have to agree with IKEA FAMILY terms and conditions and provide your personal data. If You do not provide it, you cannot join IKEA FAMILY program.
By registering for IKEA FAMILY loyalty programme membership you also create an IKEA account. You can find more information on IKEA account in Paragraph 1.1.
By providing personal data you approve that personal data are accurate and correct. In cases of inaccuracies you should immediately correct them. You can correct information about yourself which was provided by registering IKEA FAMILY card in your IKEA account.

Direct marketing (offers, surveys, events and etc.) for IKEA FAMILY members  
Categories of personal data  Legal basis for the processing
Name, date of birth, country, gender, the fact of having children under 12 years old, city, language, purchase history using IKEA FAMILY card (date and time of a purchase, receipt number, names of goods, quantities, prices, total amount of purchases), IKEA FAMILY card number, 
e-mail, tracking interactions of e-mail (information if a newsletter was read, when it was read, how many times it has been read (or opened), if it has forwarded, what operating system was used, which email server, including its location).
We are processing personal data for direct marketing purposes based on your consent, also based on our legitimate interest to offer products and/or services that better meet your needs we are doing profiling.

We are sending you information about our products, services, offers & promotions but we are doing so only when you give us consent to receive this information. 
If you agreed to receive direct marketing by e-mail in order to better understand if information we send is relevant to you we track interaction of newsletter (information if a newsletter was read, when it was read, how many times it has been read (or opened), if it has forwarded, what operating system was used, which email server, including its location). 
Also, we provide for you particular direct marketing offers based on profiling, i.e. based on your age, country, gender city, the fact of having children under 12 years old, purchase history in order to offer products and/or services that better meet your needs.
Sometimes we could invite you to special events or ask you to participate in surveys, e.g. which items you prefer, why you buy this or that item, or how your dream home looks like. We do that to learn more about your preferences and to better tailor our offerings to your needs. This information is purely voluntary and you are not obliged to answer these surveys or participate in the event.
You can unsubscribe IKEA FAMILY direct marketing by changing your choices in IKEA account, by clicking unsubscribe link in e-mail or contacting us by below mentioned contacts.

Games and/or competitions for IKEA FAMILY card holders
Categories of personal data Legal basis for the processing
Name, surname, purchase history using IKEA FAMILY card (date and time of a purchase, receipt number, names of goods, quantities, prices, total amount of purchases), IKEA FAMILY card number, e-mail, phone.

In case of winning: name, surname, personal identification code, value of a prize and/or any other gift, signature, address (in cases when the prize or any other gift is delivered home). 
Your consent. 
In case of winning the legal basis for data processing is our legal duty.
If any complaint with regard to a game/lottery and/or competition is received, personal data processing is then based on a legitimate interest to protect our rights. 

When registering IKEA FAMILY card or having logged in to your IKEA account, you can decide, whether you want to participate in games and/or competitions for IKEA FAMILY card holders. Participation is not obligatory, you are free to choose. Having expressed a consent to participate in games and/or competitions, you agree and understand that your details in relation to IKEA FAMILY card which you provided earlier, once the terms and conditions of a game and/or competition are met, will be automatically included in all games and/or competitions for IKEA FAMILY card holders organised by us without any additional registration or notification. You also agree that in case of winning IKEA FAMILY number will be publicly announced on the website of the competition and/or game or on social networks.
If you have agreed to participate in games and/or competitions for IKEA FAMILY card holders, we will process your personal data for the purposes of organisation, execution, administration of games and/or competitions, determination of winners, announcement of winners, presentation of prizes and/or other gifts; also, in case winning, personal data is processed with the aim to ensure appropriate fulfilment of our tax obligations: calculate taxes and declare information about any payments/benefits to you to tax institutions. If a complaint is received with regard to games and/or competitions, in such case personal data is processed so as to lay claims, satisfy claims or defend legal claims.
You have the right to withdraw your consent to collect and process your personal data for the purpose of games and/or competitions for IKEA FAMILY card holders any time, without prejudice to lawfulness of data collection and processing before the withdrawal of the consent. You can do that in your IKEA account or by contacting us (contact details are provided below).
For more details about how we process personal data for the purpose of games and/or competitions, how long we retain such data and whom we transfer it, see our General Privacy Policy in Paragraph 1.9.

1.3. Statistical analysis
Categories of personal data Legal basis for the processing
Date of birth, country, gender, the fact of having children under 12 years old, city, language, purchase history using IKEA FAMILY card, lists of goods, list of favourite goods Our legitimate interest, which means collection of statistical data and  preparation of reports required for the purposes specified below.

We also process your aggregated personal data by automated means for statistical purposes, for instance, we analyse what goods were added to the list of favourite goods since such details help us have a generalized overview of IKEA customer, to determine market strategies, and once we know the needs of our IKEA customers – to improve the IKEA products and services. Actions of statistical analysis have no legal or any similar significant effect. 
1.4. Direct marketing 
Categories of personal data Legal basis for the processing
If you have created the IKEA account: name, e-mail, tracking interactions of e-mail (information if a newsletter was read, when it was read, how many times it has been read (or opened), if it has forwarded, what operating system was used, which email server, including its location), lists of goods, a list of favourite goods, optional: gender, the fact of having children under 12 years old, city, language.

If the IKEA account has not been created: name, e-mail, tracking interactions of e-mail (information if a newsletter was read, when it was read, how many times it has been read (or opened), if it has forwarded, what operating system was used, which email server, including its location)
We are processing personal data for direct marketing purposes based on your consent, also based on our legitimate interest to offer products and/or services that better meet your needs we are doing profiling.

If you give us a consent in our web-page to receive direct marketing offers we are sending by e-mail information about our products, services, offers & promotions. Sometimes we could invite you to special events or ask you to participate in surveys, e.g. which items you prefer, why you buy this or that item, or how your dream home looks like. We do that to learn more about your preferences and to better tailor our offerings to your needs. This information is purely voluntary and you are not obliged to answer these surveys or participate in the event.If you agreed to receive direct marketing offers by e-mail in order to better understand if information we send is relevant to you we track interaction of newsletter (information if a newsletter was read, when it was read, how many times it has been read (or opened), if it has forwarded, what operating system was used, which email server, including its location). 
In addition, if you have created the IKEA account and provided additional data of your choice, we provide for you particular direct marketing offers based on profiling, i.e. based on your age, country, gender city, the fact of having children under 12 years old, lists of goods, a list of favourite goods in order to offer products and/or services that better meet your needs.
You can unsubscribe from direct marketing offers in IKEA account, by clicking unsubscribe link in e-mail or contacting us by below mentioned contacts.
By registering for a direct marketing offers, you confirm that your personal data is accurate and correct, and you are at least 18 years of age.

2.    How do we collect information about you?
We obtain information about you when you provide personal data to us by registering for IKEA FAMILY card, use your IKEA FAMILY account, contact us, use the card, subscribe a newsletter.

3.    How long do we keep your personal data?
Your IKEA FAMILY personal data (including direct marketing to IKEA FAMILY members) will be stored until you terminate your membership in IKEA FAMILY or otherwise request us to delete your data, or 5 years from last use of IKEA Family card in store. 
Your personal data in IKEA account will be stored 5 years from the last login. 
Data for the purposes of statistical analysis will be stored for the same period as the data of IKEA account or IKEA FAMILY data.
Personal data for direct marketing in web-page will be stored as long as you want to receive direct marketing from us, but not more than 6 months after the last interaction with the newsletter. 
4.    To whom personal data are disclosed?
We disclose your personal data to:
a)    Companies we work with
The personal data are disclosed to companies that provides services to us i.e. IT maintenance companies, media agencies, company which platform we are using for sending newsletters, UAB “Felit”. These companies are required to adequately safeguard your personal data and not use them for any unauthorised purposes and to ensure that its suppliers do the same.
b)    Other
In case of dispute we transfer your personal data to legal advisers.
c)    State and local government institutions, other persons performing functions assigned to them by law
We transfer your personal data to state and local government institutions and other persons performing functions assigned to them by law upon their request or in order to meet our legitimate interest in establishing, claiming and defending legal claims.

5.    Protection of personal data
We take the following precautions in relation to the personal data you provide us:
a)    Security
We use a variety of technical and organisational security measures to protect your personal data. Your personal data are stored safely and are only accessible to a limited number of persons.
b)    International transfers
We are always seeking to process your personal data within the European Union/European Economic Area. However, we have service providers and business partners in many parts of the world. In some cases, we might have to transfer your information to one of the companies located outside the European Economic Area. We do our best to keep your information safe in these cases, so we can rely on the European Commission's adequacy decisions. This means that the European Union believes that national laws or arrangements ensure the proper protecprotection of your personal data. If we want to store your information in the United States, we will use the "Privacy Shield", i.e. agreement between the European Union and the US governments. In cases where there is no adequacy decision, we sign a contract that includes standard terms or other approved items, codes of conduct, certificates etc. adopted by the European Union. 
You can obtain more information on personal data protection measures by submitting a separate application to us.

6.    Your rights 
Your rights are:
a)    the right to access - you have the right obtain from us confirmation as to whether or not we process your personal data and, where we do, access to the personal data. That’s why we inform you in advance about our processing activities via this privacy policy. If you have any questions, or would you like to learn more about what information we process from you, you are always welcome to contact us and we will provide you with further information;
b)    the right to rectification - you have the right to request that we correct any inaccurate personal data. Also You can correct your personal data in IKEA account.
c)    the right to erase - in some circumstances you have the right to the erasure of your personal data, if you believe there’s no longer any need for us to keep it. Or, if you previously have given your permission, you can just decide to withdraw it. This does not apply if where processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation or for the establishment, exercise or defence of legal claims;
d)    the right to receive yourself or transfer your personal data to another company in certain circumstances (known as the right to data portability). This applies when data processing is based on you consent or on a contract and where processing is carried out by automated means;
e)    the right to restrict - in some circumstances you have the right to restrict the processing of your personal data. This means we will continue to store your information, but we’ll temporarily stop any other processing. Why would you want to do this? For example if you’ve asked us to fix incorrect information. In this situation you may want us to stop processing until the information is correct;
f)    the right to object - you have the right to object to our processing. This applies when data processing is based on legitimate interests pursued by us or by a third party. You can do this when you believe that your personal interest outweighs ours; 
g)    the right to object - you have the right to object to our processing of your personal data for direct marketing purposes, including profiling;
h)    the right to withdraw your consent to the processing at any time.

To carry out mentioned rights please provide written request to us or to Data protection officer with the contact information mentioned below.

You also have the right to make a complaint to the Data state inspectorate (http://www.dvi.gov.lv/en/) if you believe that the processing of personal data by us does not comply with applicable legislation.

7.    Changes to our privacy policy
We keep our Privacy policy under regular review. This privacy policy was updated on 16 August 2018.

8.    Contact information
If you have questions about the processing of your personal data, requests or if you would like to give us feed-back, please contact:
SIA Paul Mason Properties, registration number LV50103951541, legal address: Bikeru st. 2, Dreilini, Stopiņu district, LV-2130, Latvia, phone number: +371 63301000, email address: info@IKEA.lv.

Data protection officer: dpo@IKEA.lv 
You also can contact our Data protection officer by sending a letter to us at the above mentioned address and addressing it to the Data protection officer.