Privacy Policy

1 Introduction

1.1 General

David Gotlib LLC (hereinafter “We” or “Us”) respects the privacy of every visitor to our Website (hereafter: Visitor) www.davidgotlib.com and every person who places an order and relies on our services (hereafter: Customer). Accordingly, We will only collect and use personal data in the manner described herein and in accordance with our obligations and rights under applicable privacy laws.

Transparency is a crucial part of this privacy legislation and forms the basis of this Privacy Policy. We also take into account principles such as proper and careful processing.

Accordingly, this Privacy Policy is therefore applicable when We act as controller for the processing of personal data through our Website, in other words, when We determine the purpose and means of processing that personal data.

Please read this Privacy Policy carefully and make sure you understand it well.

1.2 What are personal data?

Personal data is any information about a natural person that can be directly or indirectly identified.  It may include obvious information, such as your name and contact details, but also less obvious information, such as identification numbers, electronic location data and other online identifiers.

2 Contact details

You can contact Us:

(a) by post, to the following postal address; or

David Gotlib LLC
1345 Avenue of the Americas
2nd floor
New York, NY 10105

(b) via the contact form on our Website.

3 What personal data do we process, and how are these data used?

3.1 Information processing

Personal data Processing purpose Retention period (*)
Usage Data from Users and Customers:

  • IP address;
  • geographical location;
  • browser type and version;
  • operating system;
  • reference source;
  • duration of your visit;
  • page views and website navigation paths, as well as information about the timing, frequency, and pattern of your use of the service.
We process the usage data via cookies. These usage data can be processed so that the Website can function technically properly and to analyse the use of the Website and services. See the Cookie Policy on this Website.
Communication Data from Users and Customers:

  • Name
  • Email address

 

The source of the communication data is the information you provide to Us when you contact Us. The communication data may be processed for the purpose of communicating with you and maintaining records. Personal information is retained until we believe you are satisfied with our response.
Transaction Data from Customers:

  • Contact details
  • Card details

 

The source of the transaction data is the information You provide to Us when You make purchases through Our Website.

Transaction Data may be processed for the purpose of delivering the purchased goods and services and keeping proper records of those transactions.

Personal data will be kept for the duration of the contract. After termination of the agreement, personal data will be kept for another seven years in order to comply with the legal obligation (tax obligation).
Customer data:

  • Name;
  • First name;
  • Address;
  • Telephone number;
  • E-mail address;
  • Log-in details.
Customer management: customer administration, order management, deliveries, invoicing, checking creditworthiness, support and complaint monitoring. Personal data will be kept for the duration of the contract. After termination of the agreement, personal data will be kept for another seven years in order to comply with the legal obligation (tax obligation).

(*) Notwithstanding the above, We may retain your personal information when necessary to comply with a legal obligation to which We are subject, or to protect your vital interests or the vital interests of another natural person.

3.2 Processors

A processor is someone who processes personal data at the request of or on behalf of Us. We may sometimes enter into a contract with this party to provide certain products and/or services. In other words: We make use of processors, when this is necessary for the provision of services. In this case, We will enter into a written agreement with the processor whereby the security of your personal data is guaranteed by the processor. The processor always acts according to our instructions.

Moreover, our sister company of Europe, David Gotlib (Antwerp), can have access to the US data. To this end, we have entered a written agreement with the European entity, having the capacity of processor when accessing US data.

We appeal to the following categories of processors:

  • Companies we have engaged for ICT technical support and hosting purposes;
  • Companies we have engaged for analytical purposes;
  • Our affiliate (sister company) (United States – headquarter New York);
  • Companies we have engaged for marketing purposes;
  • Companies we have engaged for administrative purposes (e.g. CRM system);
  • Companies we have engaged for logistic purposes (e.g. order picking, delivery, etc.);
  • Companies we have engaged for payment purposes.

4 Providing your personal data to third parties

In principle, We will not share your personal data with third parties (other than processors) for any purpose, unless you have given us your consent beforehand or when We are subject to the exception below.

In some circumstances, We may be required by law to share certain personal data, including yours, if We are involved in legal proceedings or to comply with legal obligations, a court order, or the instructions of an authorized government agency.

5 International transfer of your personal data

In principle, we process personal data within the United States. Our sister company in the European Union has access to US customer data. The US customer data is stored in a datacenter in the EU and Our sister company in the EU has screen access (for operational purposes) to the US data. This means that there is a transfer of US data to the EU.

6 Security of your personal data

We will take appropriate technical and organizational measures to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

7 Modifications

We may update this policy from time to time by publishing a new version on our Website. This may be necessary, for example, if the law changes, or if We change things in a way that affects the protection of personal data. We encourage you to check this page from time to time to ensure that you are happy with any changes to this privacy policy.

8 Your rights

8.1 The guarantee of a legitimate and secure process of your personal data

Your personal data is only processed for the purposes explained in point 3. Your personal data is collected and processed in an appropriate, relevant and non-excessive manner, and is not kept longer than necessary to achieve the intended purposes.

8.2 Right to access

If you can prove your identity, you have the right to obtain information about the processing of your personal data. Thus, you have the right to know the purposes of the processing, the categories of personal data concerned, the categories of recipients to whom the personal data is transmitted, the criteria used to determine the data retention period, and the rights that you can exercise on your personal data.

8.3 Right of rectification

Inaccurate or incomplete personal data may be corrected. It is primarily the responsibility of the User to make sure he fills in the correct information, but he can also request us in writing to correct the information.

8.4 How to exercise your rights

If you wish to exercise your rights, you must send a written request and proof of identity by registered mail to DAVID GOTLIB, 1345 Avenue of the Americas 2nd floor, New York, NY 10105 or by email to [email protected]. We will respond as soon as possible, and no later than one (1) month after receipt of the request.

9 Updating your personal data

Let us know if the personal information We hold about you needs to be corrected or updated.