Privacy Policy


Privacy Policy of

This Application collects some Personal Data from its Users.


Data Controller and Owner



Types of Data collected

The owner does not provide a list of the Personal Data types collected.

Other Personal Data collected may be described in other sections of this privacy policy or by a dedicated explanation contextually with the Data collection. The Personal Data may be freely provided by the User, or collected automatically when using this Application. Any use of Cookies or other tracking tools - by this Application or by the owners of third-party services used by this Application, unless stated otherwise, serves to identify Users and remember their preferences, for the sole purpose of providing the service required by the User. Failure to provide certain Personal Data may make it impossible for this Application to provide its services.

Users are responsible for any Personal Data of third parties obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.


Mode and place of processing the Data

Methods of processing

The Data Controller processes the User's Data in a proper manner and shall take appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.

Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases the Data may be accessible to certain types of persons in charge involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.


The Data is processed at the Data Controller's operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller.

Retention time

The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Data Controller suspend or remove the data.


The use of the collected Data

The Data concerning the User is collected to allow the Owner to provide its services, as well as for the following purposes: platform services and hosting, and registration and authentication.

The Personal Data used for each purpose is outlined in the specific sections of this document.


Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Platform services and hosting

These services have the purpose of hosting and running key components of this Application, therefore allowing the provision of this Application from within a unified platform. Such platforms provide a wide range of tools to the Owner, e.g. analytics, user registration, commenting, database management, e-commerce, and payment processing, which imply the collection and handling of Personal Data. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored. is a website provided by, which allows the Owner to build, run and host this Application.

Personal Data collected: various types of Data as specified in the privacy policy of the service.


Registration and authentication

By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, this Application will be able to access some Data, stored by these third-party services, for registration or identification purposes.

Log In with PayPal (PayPal Inc.)

Log In with PayPal is a registration and authentication service provided by PayPal Inc. and is connected to the PayPal network.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: See the PayPal privacy policy – Privacy Policy



Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Data Controller, in court or in the stages leading to possible legal action arising from improper use of this Application or the related services.

The User declares that they are aware that the Data Controller may be required to reveal their Personal Data at the request of public authorities.

Additional information about the User's Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record the interaction with this Application (system logs) or other Personal Data used for this purpose (such as IP addresses).

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.

User rights

Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their content and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into an anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller via the contact information set out above.

This Application does not support “do not track” requests.

To determine whether any of the third-party services it uses honour “do not track” requests, please read their privacy policies.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using this Application and can request that the Data Controller remove their Personal Data. Unless stated otherwise, the prevailing privacy policy applies to all Personal Data the Data Controller has about Users.

Information about this privacy policy

The Data Controller is responsible for this privacy policy, prepared starting from the modules provided by Iubenda and hosted on Iubenda's servers.


Definitions and legal references

Personal Data (or Data)

Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.

Usage Data

Information collected automatically from this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilised by the Users of this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilised to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilised by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.


The individual using this Application, which must coincide with or be authorised by the Data Subject to whom the Personal Data refers.

Data Subject

The legal or natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural person, legal person, public administration or any other body, association or organisation authorised by the Data Controller to process the Personal Data in compliance with this privacy policy.

Data Controller (or Owner)

The natural person, legal person, public administration or any other body, association or organisation with the right, also jointly with another Data Controller, to make decisions regarding the purposes and the methods of processing of Personal Data and the means used, including security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application

The hardware or software tool by which the Personal Data of the User is collected.


Legal information

Notice to European Users: this privacy statement has been prepared in fulfilment of the obligations under Art. 10 of EC Directive no. 95/46/EC, and under the provisions of Directive 2002/58/EC, as revised by Directive 2009/136/EC, on the subject of Cookies.

This privacy policy relates solely to this Application.


Terms and Conditions of Personal Data Protection

I. Basic Provisions

  1. Under Art. 4, par. 7 of Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as the “GDPR”) the controller of the personal data is AVOS TRADE INTERNATIONAL LTD, ID No GB 254 6260 08 with its registered office at 3 GOWER STREET, LONDON, WC1E 6HA, UNITED KINGDOM (hereinafter referred to as the “Controller”).
  2. Controller’s contact data: Address: 3 GOWER STREET, LONDON, WC1E 6HA, UNITED KINGDOM e-mail: 
  3. Personal data means any information relating to an identified or identifiable natural person (the “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  4. The Controller has not/has appointed a data protection officer. The contact data of the data protection officer: AVOS TRADE INTERNATIONAL LTD, 3 GOWER STREET, LONDON, WC1E 6HA, UNITED KINGDOM

II. Sources and Categories of Processed Personal Data

  1. The Controller processes the personal data provided by you or personal data obtained by the Controller in performing your purchase order.
  2. The Controller processes your identification and contact data and the data necessary for performing the Agreement.

III. Legal Reason and Purpose for Processing Personal Data

  1. The legal reasons for processing personal data include
  • Performing the Agreement between you and the Controller under Art. 6, par. 1, subpar. b) of the GDPR,
  • The Controller’s legitimate interest in performing direct marketing (in particular for sending business communication and newsletters) under Art. 6, par. 1, subpar. f) of the GDPR,
  • Your consent to processing for the purpose of performing direct marketing (in particular for sending business communications and newsletters) under Art. 6, par. 1, subpar. a) of the GDPR in association with Section 7, par. 2 of Act No. 480/2004 Coll. on Certain Information Society Services if no purchase order for goods or services has been placed.
  1. The purpose of processing the personal data is
  • performing your purchase order and exercising the rights and obligations resulting from the contractual relationship between you and the Controller. When placing the purchase order you are requested to provide the personal data necessary for successful performance of the purchase order (name and address, contact data). The personal data must be provided for the purpose of signing and performing the Agreement. If the personal data are not provided, the Controller cannot sign or perform the Agreement,
  • sending business communications and carrying out other marketing activities.
  1. The Controller performs automated individual decisions under Art. 22 of the GDPR. You have provided consent to such processing.

IV. Data Retention Period

  1. The Controller keeps personal data
  • for the period necessary to exercise the rights and obligations resulting from the contractual relationship between you and the Controller and asserting the claims from such a contractual relationship (for a period of 15 years from the termination of the contractual relationship).
  • until withdrawal of the consent to processing the personal data for marketing purposes, but no longer than 5 years, if the personal data are processed with consent.
  1. After the lapse of the personal data retention period, the Controller will delete the personal data.

V. Recipients of the Personal Data (subcontractors of the Controller)

  1. Recipients of the personal data include the persons
  • participating in supplying the goods / services / performance of payments under the Agreement,
  • providing the service of operating the e-shop (Shoptet) and other services related to the operation of the e-shop,
  • ensuring marketing services.
  1. The Controller does not intend to transfer the personal data to a third country (outside the EU) or to an international organisation. Recipients of the personal data in third countries include the providers of e-mailing services / cloud services.

VI. Your Rights

  1. Under the provisions of the GDPR you have the right to
  • access your personal data under Art. 15 of the GDPR
  • rectification of personal data under Art. 16 of the GDPR, or the right to restriction of processing under Art. 18 of the GDPR
  • erasure of personal data under Art. 17 of the GDPR
  • object to processing under Art. 21 of the GDPR
  • data portability under Art. 20 of the GDPR
  • withdraw consent to processing in writing or electronically via the address or e-mail Controller referred to in Art. III hereof
  1. You have the right to file a complaint with the Personal Data Protection Office if you believe that your right to privacy has been violated.

VII. Terms and Conditions for Securing Personal Data

  1. The Controller declares that it has adopted all appropriate technical and organisational measures to secure the personal data.
  2. The Controller has taken technical measures to secure the data storages and personal data storages in physical form.
  3. The Controller declares that only persons authorised by it have access to the personal data.

VIII. Final Provisions

  1. By sending a purchase order via the online order form, you acknowledge that you are familiar with the privacy policy and that you accept it in its entirety.
  2. You agree with these terms and conditions by ticking the consent box in the online form. By confirming your consent, you acknowledge that you are aware of the privacy policy and that you accept it in its entirety.
  3. The Controller is entitled to change these terms and conditions. A new version of the privacy policy will be published on its website, and the new version of these terms and conditions will be sent to the e-mail address that you have provided to your Controller.

These terms and conditions come into effect on 17th September 2018