Privacy and Cookie Policy

The website https://www.davidgotlib.com/ (hereafter: the “Website”) is offered by:

David Gotlib LLC. (hereafter ‘DG’, ‘DAVID GOTLIB’ or ‘we’)

1345 Avenue of the Americas 2nd floor
New York
NY 10105

Company number: 81-3296534

If you have any questions or comments to make, you can contact us via

Email: info@davidgotlib.com
Tel.: +1 2128786080

1. Why this Privacy Policy?

Every person who visits or uses the Website (hereafter: the “Visitor”) as well as every person who relies on our services (hereafter: the “Customer”) will in most cases disclose a certain amount of personal data. The personal data is information which allows DAVID GOTLIB to identify you as a natural person, regardless of whether we actually do this. You are identifiable as soon as it is possible to create a direct or indirect link between one or more data and you as a natural person. The Visitor and the Customer are hereinafter also jointly referred to as the “Data Subject“.

We only use and process your personal data in accordance with the GDPR and any replacement legislation, or any similar regulation under any applicable law, and any regulatory requirements or codes of practice governing the use, storage or transmission of personal data. Every reference in this Privacy Policy to the ‘GDPR’ is a reference to the Regulation 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 (General Data Protection Regulation).

Through this Privacy Policy, every User of the Website is informed of the processing activities DAVID GOTLIB may carry out with his or her personal data. DAVID GOTLIB reserves the right to modify this Privacy Policy at all times. Every substantial change will be clearly communicated towards the User. We advise you to consult this document regularly.

2. Who is responsible for the processing of personal data?

2.1. Controller

DAVID GOTLIB is responsible for the processing and decides alone or in cooperation with others which personal data is being collected as well as the purposes and the technical and organisational means with regard to the processing of this personal data.

DAVID GOTLIB has taken appropriate technical and organizational measures to protect the personal data of its Visitors and Customers. DAVID GOTLIB uses various adequate security technologies and procedures to protect your personal data against unauthorized access, use or disclosure. DAVID GOTLIB ensures that your personal data is stored safely in a controlled environment.

2.2. Processor(s)

DAVID GOTLIB is free to rely on data processors. A processor is the natural or legal person who processes your personal data upon request and on behalf of the data controller. The processor is required to ensure the security and confidentiality of the data. The processor shall always act on the instructions of the data controller.

DAVID GOTLIB relies on the following categories of “processors”:

  • Companies we have engaged for marketing purposes;
  • Companies we have engaged for ICT technical support and hosting 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 analytical purposes;
  • Companies we have engaged for payment purposes.

With a view to the optimal protection of the personal data of our customers, we have made the necessary contractual arrangements with the aforementioned data processors to ensure that they apply the highest privacy standards. In any event, data processors shall be required to ensure the security and confidentiality of the personal data.

As a resident of the European Economic Area, a transfer of your personal data outside the European Economic Area (EEA) can only take place to countries that the Data Protection Authority has found to provide the same adequate level of protection or, if this is not the case, to the extent that DAVID GOTLIB has made the necessary contractual arrangements, taking into account the standard provisions as imposed by the Data Protection Authority, to ensure that your personal information receives an adequate level of protection.

3. On what legal grounds is your personal data processed?

In accordance with the GDPR we process personal data on the following legal grounds:

  • On the basis of the execution of the contract agreed upon with the Customer or the execution of pre-contractual steps taken at the request of the Data Subject; or
  • On the basis of compliance with legal or regulatory provisions with regard to the management of the contractual relationship with the Customer, invoicing in particular;
  • On the basis of our legitimate interest in responding to information requests from Visitors and Customers;
  • On the basis of our legitimate interest in sending promotional offers (direct marketing) to our Customers;
  • On the basis of the explicit consent to send promotional offers (direct marketing) to Visitors.

4. Which personal data is processed?

DAVID GOTLIB commits to only collect and process your personal data in a way that is adequate, relevant and limited to what is necessary for the purposes for which they are processed.

How much and what personal information DAVID GOTLIB collects about you depends on your use of the Website and/or of our services. The collection of personal data will be further expanded as more intensive use is made of our Website and our services. In general, Customers will provide more personal data than Visitors. The following categories of personal data are processed by DAVID GOTLIB:

Customers:

  • Personal identification data (name, first name, address, login details);
  • Contact details (telephone number and e-mail address);
  • Financial identification data (bank details);

This personal data is collected when the Customer places an order via our Website. Other personal data may be collected at a later date, for example in the context of our after-sales service.

Visitors:

  • Personal identification data (name, e-mail address);
  • Electronic identification data (IP address, location, cookies);

This personal data is collected when you visit our Website and, in particular, when you fill out and submit our contact form.

5. For which purposes is your personal data used?

The processing of your personal data is essential for the proper functioning of the Website and the provision of associated services. The collection of personal data becomes more extensive as the User makes more intensive use of our Website and our online services.

DAVID GOTLIB commits to solely process your personal data for the following purposes:

Customers:

  • Customer management: customer administration, order management, deliveries, invoicing, checking creditworthiness, support and complaint monitoring.

Visitors:

  • Answering requests for information submitted via the contact form on the Website;

The Data Subject’s personal data may also be used for the following purposes:

  • Dispute management.
  • Protection against fraud and criminal offences.

We also use cookies in order to recognise the (IP address of) Visitors and to offer them a personalised user experience, to remember technical choices and to detect and correct any errors which might be present on the Website. For more information concerning the use of cookies, we kindly refer you to item 9 below.

When visiting the Website, some data is being collected for statistical purposes. Such data is necessary to optimise your user experience. It concerns the following data: probable location of consultation, hour and day of the consultation and the pages which are being consulted, etc. In order to protect your privacy in the best possible way, this data is always anonymized.

The User provides the personal data to DAVID GOTLIB himself and therefore retains a certain degree of control. DAVID GOTLIB reserves the right to suspend or cancel certain operations if the required personal data is missing, incorrect or incomplete.

6. Who receives your personal data?

Your personal data will only be processed for internal use within DAVID GOTLIB. Your personal data will not be sold, passed on or communicated to third parties, unless you have given us your explicit consent beforehand, or if the transmission is necessary for the execution of the agreement or is legally required.

7. How long do we store your personal data?

Your personal data is stored as long as necessary to achieve the purposes pursued. Your personal data will be erased from our database as soon as it is no longer necessary for the purposes pursued or if you validly exercise your right to erasure.

8. What are your rights?

8.1 Guarantee of a legitimate and secure process of your personal data

Your personal data is solely processed for the legitimate purposes explained in point 5. Your personal 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 to rectification of your personal data

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 rectify the information.

8.4 Right to erasure (or “right to be forgotten”)

You also have the right to obtain the erasure of your personal data under the following assumptions:

  • Your personal data is no longer necessary for the intended purposes;
  • You withdraw your consent to the processing and there is no other legal ground for processing;
  • You have validly exercised your right of opposition;
  • Your personal data has been illegally processed;
  • Your personal data must be deleted to comply with a legal obligation.

The deletion of personal data is mainly related to visibility; it is possible that the deleted data are still temporarily stored.

8.5 Right to limitation of processing

In certain cases, you have the right to request the limitation of the processing of your personal data, especially in case of dispute as to the accuracy of the data, if the personal data is necessary in the context of legal proceedings or the time required to DAVID GOTLIB to verify that you can validly exercise your right to erasure.

8.6 Right to object

You have the right to object at any time to the processing of your personal data for direct marketing purposes. DAVID GOTLIB will stop processing your personal data unless it can demonstrate that there are compelling legitimate reasons for the processing which prevail over your right to object.

8.7 Right to data portability

You have the right to obtain any personal data which you have provided us in a structured, commonly used and machine readable format. At your request, this data may be transferred to another provider unless it is technically impossible.

8.8 Right to withdraw your consent

You may withdraw your consent to the processing of your personal data at any time, for example for direct marketing purposes.

9. Cookies

A cookie is a small text file that is placed on the hard disk of your computer or mobile device when you visit a website. The cookie is placed on your device by the website itself (“first party cookies”) or by partners of the website (“third party cookies”). The cookie identifies your device by a unique identification number when you return to the website and collects information about your browsing behaviour.

There are different types of cookies. We use the following cookies on our website according to their purposes: essential or strictly necessary cookies and non-essential cookies (functional and analytical cookies);

Webshop

Cookie “wc_cart_hash_#”

  • Purpose: Helps WooCommerce determine changes to the content/data of the shopping cart.
  • Type: functional
  • Retention period: 1 session

Cookie “wc_fragments_#”

  • Purpose: Stores a visitors login information so they don’t need to keep logging in if browser closed.
  • Type: functional
  • Retention period: 1 session

Cookie “woocommerce_items_in_cart”

  • Purpose: Used by WooCommerce to store items in your cart when making a purchase
  • Type: functional
  • Retention period: 1 session

Cookie “woocommerce_warehouses”

  • Purpose: Is generated website to track stock levels from different locations and is required for our site to function.
  • Type: functional
  • Retention period: 1 month

Cookie “wp_woocommerce_session_”

  • Purpose: Contains a unique code for every visitor, so that it knows where the data of the shopping cart can be found for each customer.
  • Type: functional
  • Retention period: 2 days

Cookie “aelia_cs_selected_currency”

  • Purpose: Used to remember which currency prices should be displayed in for website users
  • Type: functional
  • Retention period: 1 day

Google Analytics

Cookie “_ga”

  • Purpose: Registers a unique ID that is used to generate statistical data on how the visitor uses the website.
  • Type: analytical
  • Retention period: 2 years

Cookie “_gat”

  • Purpose: Used by Google Analytics to throttle request rate.
  • Type: analytical
  • Retention period: 1 day

Cookie “_gid”

  • Purpose: Registers a unique ID that is used to generate statistical data on how the visitor uses the website.
  • Type: analytical
  • Retention period: 1 day

Cookie “collect”

  • Purpose: Used to send data to Google Analytics about the visitor’s device and behavior. Tracks the visitor across devices and marketing channels.
  • Type: analytical
  • Retention period: 1 session

Vimeo

Cookie “vuid”

  • Purpose: Collects data on the user’s visits to the website, such as which pages have been read.
  • Type: analytical
  • Retention period: 2 years

Doubleclick

Cookie “IDE”

  • Purpose: Used by Google DoubleClick to register and report the website user’s actions after viewing or clicking on e of the advertiser’s ads with the purpose of measuring the efficacy of an ad and to present targeted ads to the user.
  • Type: analytical
  • Retention period: 1 year

Cookie “test-cookie”

  • Purpose: Used to check if the user’s browser supports cookies.
  • Type: functional
  • Retention period: 1 day

10. 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 info@davidgotlib.com We will respond as soon as possible, and no later than one (1) month after receipt of the request.

11. Possibility to lodge a complaint

If you have any comments or complaints about the way in which we handle your personal data, we ask you to report them to us first. In this way, we can reach an amicable solution by mutual agreement.

If, after this notification, you are still not satisfied with the processing of your personal data by DAVID GOTLIB, you have the right to lodge a complaint with the competent Data Protection Authority.