This website is operated and maintained by Virag Wholesale (hereinafter referred to as viragwholesale.com or the Company)
This electronic document, referred to henceforth as the Privacy Policy (the “Policy“) informs you about the collection, use and transfer of data about you during your use of this website.
1. Definitions
Website means this website.
Service means a feature offered by the Website.
We, Us or Our means the Company.
Individual means a natural human being.
Entity means any Individual or group of Individuals recognized by law and having legal rights and obligations.
Person means any Individual or Entity.
Bot means any mechanical, or computer hardware or software construct that can be programmed by a Person to perform one or more task.
Use means accessing any content on the Website, including, but not limited to accessing web pages on the website, viewing or downloading pictures that appear on web pages or otherwise, and downloading files from the website.
User, You or Your means a Person or Bot who Uses the Website, including you.
Party means either you or us. Parties means both you and us.
Personal Data means information held by the Company that relates to a User and can be used to identify the User uniquely, either on its own or in conjunction with other information in the possession of the Company. Such information includes, but is not limited to, user names, email addresses, communication (postal) addresses and telephone numbers.
Data Subject means the identified or identifiable Person to whom Personal Data pertains.
User Data means Personal Data provided by a User to the Company.
Processing means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Controller means the Person who determines the purpose and means of Processing Personal Data.
Processor means the Person who performs Processing on Personal Data on behalf of the Controller.
Sub-processor means any Processor engaged by a Processor for processing of Personal Data.
Third Party means any Person other than the Data Subject, Controller, Processor, Sub-processor or Persons who, under the direct or indirect authority of the Controller or Processor, are authorized to process Personal Data.
Recipient means a Person to whom Personal Data are disclosed, whether a Third Party or not. However, any legally competent authority which may receive Personal Data in compliance with applicable laws and regulations shall not be regarded as a Recipient.
Supervisory Authority means a competent legal authority which has supervisory authority and legal jurisdiction over a Party.
2. Roles of the Parties
The Company is both the Controller and Processor for User Data. User acknowledges that providing data to us is completely voluntary and that the User does so of their own volition. User further acknowledges that they provide data to us for the purpose of using this Website.
The Parties acknowledge that the Company, being the Processor of data, may engage Sub-processors from time to time for the purpose of processing Personal Data.
3. What data do We collect?
The Website collects the following information from Users directly:
- Name, including first, middle and family name;
- Contact details, including email address and phone number;
- Name of the industry in which the User works;
- Name of the company, business or organization the User works for;
- User’s title or designation at the company, business or organization.
Additionally, the Website also collects data indirectly through its technology, such as Internet access logs and cookies.
4. Nature of Processing
The Parties agree that the Company Processes User Data for the following purposes:
- Identifying Users uniquely;
- Enabling Users to access Services to which they are entitled;
- Identifying usage patterns of Services for identifying potential problems or avenues of improvement; and
- Monitoring Users’ compliance with terms and conditions of the Website.
The Parties also agree that we Process shipment data for the purpose of providing shipping services offered through the Website.
5. Obligations of the Company
5.1. Processing
We shall Process data only for the purpose of providing and improving our Services, using appropriate automated and non-automated measures. We will not Process data for any other purpose. In case we are unable to comply with any of the requirements described here, we will promptly inform Users of our inability to do so, in which case Users shall be free to suspend their usage of our Services.
5.2. Confidentiality
We shall ensure that confidentiality of data is strictly maintained at all times, including informing and training our personnel about the confidential nature of data and appropriate practices and procedures for the handling of such data. We shall ensure that all personnel engaged in Processing of data have executed written confidentiality agreements and that the obligations under such agreements survive termination of the personnel engagement. This will cover both our own employees and any sub-processors engaged by us for the Processing of data.
5.3. Security
We shall ensure that data are handled in a secure and reliable manner. We shall maintain appropriate technical and procedural measures to protect against unauthorized and accidental access, loss, alteration or disclosure of data. We shall also take reasonable steps on a periodic basis to ensure that the measures put in place to protect data are being followed effectively.
5.4. Limitation of Access
We shall ensure that our access to data is limited strictly on a needs-basis to only those personnel who are responsible for providing the Services offered by us.
5.5. Notification
We shall inform a User promptly if:
- in our opinion, an instruction from the User violates any requirement of this agreement, or that of any law or regulation applicable to the protection of Personal Data;
- any non-compliance with the requirements of this agreement is detected by us;
- any notice, enquiry or investigation is received from a Supervisory Authority in relation to data provided by the User;
- a Data Subject submits a request to us, exercising right of access, right to rectification, restriction of processing, erasure (“right to be forgotten”), data portability, object to the processing, or its right not to be subject to an automated individual decision-making relating to Personal Data provided by the User.
5.6. Data Protection Officer
We have appointed a Person to act as a Data Protection Officer, who is responsible for overseeing compliance with this agreement and liaising with Users on matters related to this agreement. The appointed Person can be contacted by sending an email to privacy [at] viragwholesale.com.
6. Obligations of Users
Users, during their use of the Services, shall comply at all times with the requirements of this agreement and those of applicable data protection laws and regulations, including any requirement to notify data subjects about the Controller and Processor for the said data. The responsibility for accuracy, quality and legality of data, and the means by which such data have been acquired by a User, shall rest solely with that User. In this regard, Users specifically acknowledge that their use of the Services does not violate the rights of any Data Subject to the extent applicable under applicable laws and regulations.
7. Processing of Personal Data
Users acknowledge that in accessing certain Services through the Website, they may upload Personal Data pertaining to Data Subjects. Users hereby grant us permission to use information about their business and usage experience to enable us to provide Services to you, including updating and maintaining User Data, addressing errors or service interruptions, and to enhance the type of Services we may provide to you in the future. Users also grant us permission to combine their own data with that of others in a way that does not identify the User or any individual personally to improve Services and to compare business practices with other service standards.
We maintain appropriate administrative, physical, and technical safeguards for protection of the security, confidentiality and integrity of User Data. Those safeguards include, but are not limited to measures designed to prevent unauthorized access to or disclosure of data (other than by the Users).
Users acknowledge that they remain responsible for the data they provide as part of the Services they use on this website. It is recommended that Users verify that the security and privacy protections offered by the Services are adequate and in compliance with all applicable laws governing the type of data included in the content provided to the services.
Users further acknowledge that they are solely responsible for taking steps for maintaining appropriate security, protection and backup of data within their premises. They are solely responsible for determining suitability of the services in light of the type of your data used within the Services. We do not maintain any knowledge or control over Users’ information system(s) (whether or not integrated/interfaced with the Website) and the data Users store on their own systems, including the content, quantity, value or use of such data.
8. Company Access to your Data
Users acknowledge that the structure of the Website in connection with the Services it offers, is such that it is technically possible for our personnel to access data. Users acknowledge that the nature of Services is such that direct access by us to the data is not intended to be a Service and that any such access is purely for the purpose of keeping the Website running.
We will never disclose data to any Third Party, except:
- with prior written consent from, or as otherwise directed by the concerned User;
- to respond to duly authorized information requests of police, law enforcement, or other competent authorities;
- to comply with any applicable law, regulation, subpoena, discovery request or judicial order;
- to investigate and help prevent security threats, fraud, or other illegal, malicious, or inappropriate activity;
- to enforce/protect the rights and properties of the Company or its affiliates or subsidiaries; or
- with the prior informed consent of the Data Subject to whom the Personal Data apply.
9. Use of Cookies
Cookies are small piece of data sent by a website to a web browser, typically for the purposes of keeping a track of the person using the web browser on that particular website. Cookies can come in various shapes and forms and can be used for multiple purposes by the website that sets them. Different types of cookies and how they apply to the Website are explained below.
9.1. Tracking cookies
A tracking cookie is a temporary piece of data that a website uses to recognize a particular user and distinguish them from other users using the website at the same time.
This Website does not use tracking cookie for identifying Users uniquely.
9.2. Analytics cookies
Analytics cookies are used to study user behavior and website usage patterns with the aim of understanding how users use a website, how various website features are used and which ones the users find the most (or least) useful.
This Website uses Google Analytics, a third-party website analytics service, which uses two cookies to track the pages you visit on this website. If you are not comfortable with cookies, you may set your web browser to automatically refuse cookies from the Website. Please consult the official documentation for your web browser on the procedure for doing this.
10. Data Security
We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the information we collect through this website. Detailed information in this regard is available in our Information Security Policy.
11. Rights of Data Subjects
To the extent legally permissible, a Data Subject may submit a request to access, rectify, erasure, restrict processing of, object to processing or its right not to be subjected to automated individual decision-making in relation to their Personal Data on the platform by sending an email to the data protection officer at privacy [at]viragwholesale.com.