This privacy policy applies between you, the User of this Website and ZACKARO Ltd, the owner and provider of this Website. ZACKARO Ltd takes the privacy of your information very seriously by committing to protect the data you share with us. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website. All information is stored securely and is accessed by authorized personnel only. ZACKARO Ltd implements and maintains appropriate technical, security and organisational measures to protect Data against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure. Please read this privacy policy carefully. 
 

DEFINITIONS AND INTERPRETATION 

1. In this privacy policy, the following definitions are used:

Data

collectively all information that you submit to ZACKARO Ltd via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Act 1998; . From May 25th, 2018, the Data Protection Act will be replaced by the Regulations (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (GDPR), and ZACKARO LTD’s processing will take place in accordance with the GDPR.

Cookies

a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);

ZACKARO Ltd, or us

ZACKARO Ltd, a company incorporated in England and Wales with registered number 11764236 whose registered office is at 141, 405 Kings Road, London SW10 0BB;

UK and EU Cookie Law

the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;

User or you or you

any third party that accesses the Website and is not either (i) employed by ZACKARO Ltd and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to ZACKARO Ltd and accessing the Website in connection with the provision of such services;

Website

the website that you are currently using, http://www.mokee.eu, and any sub-domains of this site unless expressly excluded by their own terms and conditions.



2. In this privacy policy, unless the context requires a different interpretation:
 
a. the singular includes the plural and vice versa; 
b. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy; 
c. a reference to a person includes firms, companies, government entities, trusts and partnerships; 
d. "including" is understood to mean "including without limitation";
e. reference to any statutory provision includes any modification or amendment of it; 
f. the headings and sub-headings do not form part of this privacy policy. 

SCOPE OF THIS PRIVACY POLICY
3. This privacy policy applies only to the actions of ZACKARO Ltd and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites

DATA COLLECTED
4. We may collect the following Data, which includes personal Data, from you:
a. Name
b. Date of birth;
c. Gender;
d. Records of your interactions with us (e.g. if you contact our customer service team, interact with us on social media);
e. Contact Information, i.e. details necessary for the fulfilment of your orders such as delivery address, billing address, email addresses and telephone numbers;
Demographic information such as post code, preferences and interests, this may happen when we ask you to complete surveys that we use for research purposes, although you do not have to respond to them
Information you provide us when you enter a competition or participate in a survey; 
h. Details of transactions you carry through our website such as credit / debit card numbers; 
i. IP address (automatically collected); 
j. Web browser type and version (automatically collected); 
k. Operating system (automatically collected);
l. A list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);
m. in each case, in accordance with this privacy policy.
We do not store credit/debit card information nor do we share customers details with any 3rd parties

OUR USE OF DATA
For purposes of the Data Protection Act 1998, From May 25th, 2018 GDPR, ZACKARO Ltd is the "data controller"
6. We record and store all information that you enter on our Website or which you provide to us in other ways. You can decide not to provide certain information to us, through this may mean that you are unable to take advantage of some of our offers. We will retain any Data you submit for as long as necessary to fulfill the purposes we collected if for, including for the purposes of satisfying any legal, accounting or reporting requirements, but no longer than 10 years.
 
7. Unless we are obliged or permitted by law to do so, and subject to any third party disclosures specifically set out in this policy, your Data will not be disclosed to third parties. This does not include our affiliates and / or other companies within our group. 
8. All personal Data is stored securely in accordance with the principles of the Data Protection Act 1998., the GDPR from May 25th, 2018. For more details on security see the clause below (Security)
9. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons: 
processing orders, delivering goods and providing services (providing your contact details is always voluntary but necessary in order to conclude and fulfill the Sale Contract);
b. manage and respond to any queries or complaints to our customer service team; 
c. internal record keeping;
d. communication with you about orders, products, services, marketing offers and other information from ZACKARO(moKee);
e. mprovement of our products / services;
f. transmission by email of promotional materials that may be of interest to you; 
g. contact for market research purposes which may be done using email, telephone, fax or mail. 
h. the purposes of updating and maintaining our database and customer accounts; 
i. complying with our legal and regulatory obligations. We may also use your data, or permit our group companies to use your data, to provide you with information about goods and services which may be of interest to you and we or they may contact you about these by. We may contact you by post, phone, email, SMS and other electronic means. We do not supply your personal data to third parties for marketing purposes 
Such information may be used to customise or update the Website; in each case, in accordance with this privacy policy. 

CONTROLLING USE OF YOUR DATA 
We rely on the following legal basis, under GDPR, to process your personal data: 
a. the processing is necessary to perform a contract with you, or take steps prior to entering into a contract with you (e.g. where you have made a purchase with us, we use your personal data to process the payment and fulfil your order).; 
b. we have obtained your consent (e.g. where you contact us with a query, where you add optional information to your account profile, or if you consent to receive marketing from us);
c. it is in our legitimate interests as an e-commerce provider to maintain and promote our services. We are always seeking to understand more about our customers in order to offer the best products and customer experience. We use information about you to tailor your view of the Website, to make it more interesting and relevant in respect of the products and offers on view.

PASSING INFORMATION TO THE OTHERS 
11. ZACKARO Ltd philosophy is that we protect our customer data, and that this data is not passed on to third parties for advertising and marketing purposes. However, to be able to provide our service, we pass data on to third parties to the extent outlined below:
a. Affiliated companies: especially the subsidiary company Mokee Polska sp. z o. o. with its registered office in Poland, Ślusarska St 9 /2.28, 30-710 Cracow. Of course, your data are protected to the same extent as has been described previously. 
2. We commission other companies and individuals to understand duties on our behalf, e.g. parcel delivery, accounting, web development, the sending of letters or emails, maintenance of our customer lists, analysis of our databases, advertising measures, processing of payments (by credit card or electronic payment) as well as customer service. These service providers all have access to customers' personal details, restricted to those data required for the fulfilment of their duties. We are contractually obliged not to use these data for any other purposes. Furthermore, we are also obliged to handle information in accordance with this privacy policy and in accordance with the Data Protection Act 1998 and the GDPR from May 25th, 2018
13. We will make details of customer accounts and customers’ personal details public when we are legally obliged to do so

THIRD PARTY WEBSITES AND SERVICES 

14. ZACKARO Ltd may, from time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the Website. The providers of such services have access to certain personal Data provided by Users of this Website.
15. Any Data used by such parties is used only to the extent required by them to perform the services that we request. Any use for other purposes is strictly prohibited. Furthermore, any Data that is processed by third parties will be processed within the terms of this privacy policy and in accordance with the Data Protection Act 1998 and the GDPR from May 25th, 2018.

16. In order to be able to offer you Klarna’s payment options, we will pass to Klarna certain aspects of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you.

General information on Klarna you can find here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarna’s privacy policy.



LINKS TO OTHER WEBSITES
17. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them

CONTROLLING USE OF YOUR DATA
18. ZACKARO Ltd may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of ZACKARO Ltd. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us
19. We may also disclose Data to a prospective purchaser of our business or any part of it. 
20. In the above instances, we will take steps with the aim of ensuring your privacy is protected.


CHILDREN 
21.Our Websie is not intended for, and should not be used by, children under the age of 18. We do not knowingly collect personal data from children under 18. 

YOUR RIGHTS 
22. Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
a. The right to request a copy of the personal data which we hold about you; 
b. The right to request that we correct any personal data if it is found to be inaccurate or out of date; 
c. The right to request your personal data is erased where it is no longer necessary to retain such data;
d. The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
e. The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller;
f. The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
g. The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests 
23.If you wish to exercise any of the rights set out above, please contact us via contact us via the email address: tlc@mokee.eu, sending the letter to the address: 141, 405 Kings Road, London SW10 0BB, UK. 
24. We retain your basic contact information for direct marketing of our products and services until you object to their use for this purpose, or until you revoke your consent, if we process them with direct marketing consent, or if we establish that they have become outdated.
25. If you no longer want to receive marketing information form us you can change your preferences by send your withdrawal from the moKee’s newsletter at any time to us at the following address: 141, 405 Kings Road, London SW10 0BB, UK or by clicking on “Unsubscribe” link in any email. 
26.You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. 
27.We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 
28. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated 
29. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.

FUNCTIONALITY OF THE WEBSITE 
30. To use all features and functions available on the Website, you may be required to submit certain Data. 
31. You may restrict your internet browser's use of Cookies. You have the fundamental right to decide which information you make available to us. If you wish to withhold automatic information, you can find more information in the Help menu of your browser. However, you will then no longer be able to use certain functions – such as the online shop. 

SECURITY 
32. Data security is of great importance to ZACKARO Ltd and to protect your Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure Data collected via this Website. Our Website uses industry-standard Secure Sockets Layer (SSL) technology to provide encryption of personal information such as your name, address and credit card details. In this way, information passed between your computer and us cannot be read in the unlikely event of someone intercepting it
 
33. If password access is required for certain parts of the Website, you are responsible for keeping this password confidential. It is important that your protect your computer from unauthorized access if you share your computer with others
 
34. We endeavour to do our best to protect your personal Data. However, transmission of information over the internet is not entirely secure and is done at your own risk. We cannot ensure the security of your Data transmitted to the Website. 

COOKIES 
35. This Website may place and access certain Cookies on your computer. ZACKARO Ltd uses Cookies to improve your experience of using the Website and to improve our range of products and services. ZACKARO Ltd has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times. 
36. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
 
37. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling ZACKARO Ltd to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

37. This Website may place the following Cookies: 
a. performance cookies; 
b. functionality cookies; 
c. targeting and advertising cookies; 
38. Type of Cookie - PurposeStrictly necessary cookies

These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.Analytical/performance cookiesThey allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.Functionality cookiesThese are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).Targeting cookiesThese cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
 
39. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser. 
40. You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
 
41. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
 

TRANSFERS OUTSIDE THE EUROPEAN ECONOMIC AREA 
42. Data which we collect from you are not being stored and transferred to countries outside of the European Economic Area (EEA). 
43. If we transfer Data outside the EEA, we will take steps with the aim of ensuring that your privacy rights continue to be protected as outlined in this privacy policy. 

GENERAL

44. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

45. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

46. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

47. This privacy policy is governed by and interpreted according to English law. All disputes arising under this privacy policy are subject to the exclusive jurisdiction of the English courts.



CHANGES TO THIS PRIVACY POLICY

48. ZACKARO Ltd reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations. 

CONTACT
49. If you have any further questions regarding the data, or how we use it, then please feel free to contact ZACKARO Ltd by email at: tlc@mokee.eu, or in writing at: Office 141, 405 Kings Road, London SW10 0BB.
50. If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.