1. Websites and Operators of the Websites
1.1. The Pramra Global Resources GmbH company operates a Website (“Website”) available in various countries to commercialize IT&C products to end-consumers and retail legal persona (“Customers”) as follows:
www.pramraglobal.com is owned by Pramra Global Resources GmbH, a trading company, duly registered according to the Austrian legislation, having its headquarters and registered office in Marxergasse Street no. 24/2, 6th floor, room 2:2, 1030 Vienna, Austria, VAT number AT U74560138, Company Registration Number FN 515381 p;
In this document, the term “Website” shall mean and refer the up-mentioned website and includes the social platforms company pages.
1.2. Your legal relationship is with the Pramra Global Resources entity which operates the Website you are visiting and/or through which you conclude an online transaction, unless specifically stated otherwise elsewhere.
1.3. The Pramra Global Resources company reserves the right to assign in the future the operation of the Website to any other future registered company, if the case. Such change of operator of the Website will be reflected in our terms and conditions.
1.4. Pramra Global Resources GmbH, Marxergasse Street no. 24/2, 6th floor, room 2:2, 1030 Vienna, Austria, and any of its affiliates are individually and collectively referred to as “Pramra Global”. In case of doubt, the term “Pramra Global” or “we” refers to the operator of the Website you are visiting.
2.2. These terms of sale are applicable to consumers (natural persons ordering from our Website) and not to our relationship with companies (legal persons). If you are a company interested in our products, please contact us separately via the contact details available on the Website and we will respond in due time in order to settle the commercial details of your order.
5. Terms of Supply
You find the Terms of Supply referred to above under the following link: TERMS OF SALE
6. General provisions
Also, we undertake that significant national law may be applicable to each of the countries in which we operate, and we comply with such legislations is applicable, as the case may be.
6.2. Provision of personal data is voluntary; however, without providing us certain data you may not be able to receive services or purchase products from us.
7. Your data which we may collect or process
- data which you provide when you register to one of our services or to have access to restricted areas of our Website or mobile App or during a purchase process, in particular name and surname, e-mail address, sex, date of birth, billing address, delivery address and / or telephone number;
- information which you provide by filling in forms on our Website or by posting material on our Website;
- details of transactions you carry out through our Website and details of the fulfilment of your orders;
- information which you provide when you participate in a competition or promotion sponsored or organised by us or one of our affiliates;
- other marketing related data like contact or other information which you give or allow us and our third parties to use for newsletters or other marketing purposes;
- information which you provide when you contact us by any means of communication;
- information which you provide if you decide to participate in and complete surveys;
- sound recordings of telephone calls with our Customer Service;
- other profile data like your username, purchase history, your interests/references regarding our products and services and your communications with us.
7.2. Payment data, respectively bank IBAN account from which the payment was made from.
7.2.2. Only if you provide your payment data directly to us, we collect and process such data. This may be the case for example if you provide us your bank account details for a reimbursement in case of a product return.
7.4. Our contractual partners who carry out the products delivery activities you order via our Website, can request your identity card in order to identify the person who takes over the package with the person who must receive the product delivered. The courier company requesting your identity card or identification document has the right to request this document according to applicable law in some of the countries, regulating courier activities and postal services at national level, so it is not our requirement.
8. Purpose of processing your data and legal basis for processing
8.1. We may use data held about you for the following purposes:
- Carry out our obligations arising from any transaction entered into between you and us;
- Protecting our and your rights and interests;
- Ensure that content of our Website is presented to you in the most effective manner;
- Customize the actual and future shopping experience for you;
- Marketing analysis and statistical research for internal needs of Pramra Global;
- Provide you with information, products or services that you request from us;
- Send you notifications, including regarding changes to our set of terms and conditions.
9. IP address and other parameters provided by your Web browser
9.1. We may collect information about your device, including, where available, your IP address, operating system and browser type and other parameters provided when your Web browser accesses our Website.
9.2. Such other parameters may include but are not to be limited to (i) details of your visits, for example traffic data, location data and other communication data and (ii) the resources that you access.
9.3. We may use such information (i) for system administration (ii) for statistical purposes (e.g. create reports on an aggregate basis such as statistical data about our visitors’ browsing actions and patterns) and/or (iii) for fraud protection, credit risk reduction and other security purposes, for example if the behaviour on or access to our Website by you or from your device harms in any way the interests or causes any damage to Pramra Global or third parties with which Pramra Global collaborates.
9.4. We may use technical data provided to us by your Web browser to provide customized advertising to you, including through onsite targeting or re-targeting measures. The technical data provided by your Web browser will not be linked to the personal data we may have from you and will not be used to identify you. In case of onsite targeting we will use such technical data to present advertising to you, which based on the analysis of your previous clickstream, may be of particular interest to you. By applying re-targeting technology especially by certain partners we may collaborate with from time to time, we are able to provide users which have previously visited our Website, our advertisements or our products with advertisements when such user visits a third-party website which is part of the same advertising network. This form of marketing is conducted on a anonymous basis, meaning that no personal data in any way are stored and no use profile is linked to your personal data.
10. Newsletters, messages and alerts
10.1. When you provide us personal data and/or contact information through our Website, especially when you insert your e-mail address, you agree (subject to your right to refuse or revoke your consent according to the next section), that we may send you newsletters, messages and other alerts mainly by e-mail, short messages (SMS), push notifications, phone or in specific cases, by regular mail. Such communications are being sent, among others, with or without human interference for purpose of direct marketing or advertising similar products or services offered by Pramra Global.
10.2. You can refuse or revoke your consent to receive newsletters, messages or alerts at any time
- by using the special link provided in a newsletter, message and/or alert, or
- by using the option available to restrict, refuse or revoke your consent in the specific section of your profile on our Website, or
- in case of push notifications, by using the respective settings on your device, or
- by contacting our Customer Service at the contact details provided on our Website.
10.3. We reserve the right to choose whom to send newsletters, messages and/or alerts to and to remove from our databases of customers or prospective customers anyone who has given his consent to receive newsletters, messages and/or alerts without any further commitment on behalf of Pramra Global or of further notice. Removal from our website is an action we are force to take in certain conditions like the case where your behaviour prejudiced Pramra Global, other customers or any of the Pramra Global partners (ex: if you place false orders, high return rate or if we see a pattern of return to sender – it means that several consecutive orders are placed without receiving the product(s) ordered upon delivery and also if you are involved in a cyber-threat that involves our company). In such cases we will notify you as soon as possible offering the reasons of our decisions.
11. Location of data storage and processing
11.1. The data that we collect from you may be processed in, transferred to, and/or stored at a location inside the European Economic Area (“EEA”), respectively in the Netherlands.
11.2. The data that we collect from you, may also be processed to, and stored at, a location outside the EEA, subject to us having taken all required steps by the applicable law of the EU, the EEA member states relating to the transfer of personal data abroad. Such steps may include but are not limited to compliance with the Standard Contractual Clauses for transfers in the United States if such agreements can be enforced into all agreements relevant for or relating to the transfer of data outside the EEA. Disclosure of your data in relation to various partners located outside the EEA may be necessary in order for us to make our products and services available to you, whenever we work for example with companies located in the United States of America according with the Standard Contractual Clauses, although, most of these companies have operational headquarters registered at European Union level in Ireland. The retention period of these date is established in relation to the duration of the partnership between our partner and Pramra Global Resources. In other words, as long as we are in a relationship with a certain partner, they will process data through us, unless you restrict or oppose to such processing activity, case in which we will act according to GDPR on each case basis.
11.1. The data that we collect from you may be processed by staff who works for us, our affiliates, or one of our affiliates’ third-party service providers. Such staff may be engaged in, among other things, the operation of the Website, the fulfilment of your order, the processing of your payment details or the provision of support services.
11.2. We may disclose and/or transfer your personal data to any of our affiliates, which means any member of the Pramra Global Resources as well our direct, indirect and ultimate holding company and their subsidiaries (i) in the event we reorganise the way in which we provide services to our users and such data transfer or disclosure is required to provide or continue to provide services to our users and / or (ii) in case we assign from the current operator of a Website to another subsidiary or company the operation of the Website or all or parts of the rights and obligations relating to a transaction.
11.3. We may disclose your data to third party service providers (i) to implement our obligations which we have to you, including but not limited to delivery of ordered products by a courier, sending postal mail, e-mail, SMS or push notifications, or (ii) which provide services to us or our affiliates, such as data analysis, marketing assistance, advertising services, translation, payment processing, logistic or customer support services, consulting, audit or legal services, or generally in relation with the purposes as described in the section “purpose of processing your data”. Such disclosure is permitted provided that such third parties need access to the data to perform their services but may not use them for other purposes, in particular not for their own internal business purposes.
11.4. In order to identify and process payment through a third party payment service provider and avoid frauds, we may have to disclose certain of your data (such as your name and surname, country of residence, telephone number and e-mail address as well as order number and ordered product) to such third party payment service provider.
11.5. If you provide any payment data directly to us (including bank account in case of a product return), we will disclose it to third party payment service providers to the extent required to provide refund or payment to you.
11.6. Your bank, credit card or debit card issuer and a third-party payment service provider may have access or view any data or documents related to your order or purchase contract.
11.7. We may further disclose your data to third parties and subject to the provisions of applicable law:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- if the company operating the Website or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
- if we are under a duty to disclose or share your personal data in order to comply with any legal, regulatory or court obligation;
12. Legal basis for processing activities
13. Links to or from other websites
Our Website may, from time to time, contain links to and from the websites of third parties, for example third party manufacturers, distributors, advertisers, payment service providers or social media platforms such as, for example, Facebook, Instagram or Google. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility for privacy policies of or practices implemented by such third parties. Please check those policies before you submit any data to those websites.
14. Registration through a third-party website
We may provide you the possibility to register through a third-party website, in particular through a social media platform such as Facebook. In such case, you can click on the button “register with (Facebook)” in the registration form and log into the third-party website. By doing so, you give your consent that your personal data (in particular name, surname, date of birth, sex and e-mail address) is retrieved from such social media website and sent to us. If you register through such third-party websites, please note that such websites have their own privacy policies and that we do not accept any responsibility or liability for privacy policies of or practices implemented by third parties. Please check those policies before you register to our Website through such third-party website.
15. Access to information and other rights you may have
15.1. Where you want to make use of such rights, please address your request in writing (e-mail or signed and dated letter) to the Customer Service at the address indicated on our Website, before you address to the competent Supervisory Authorities as we will try to solve any issue with undue delay.
15.2. Applicable laws provide you rights with regard to your data. Such rights include, but are not limited to:
- right to access your personal data or to see a copy of the personal data that we hold about you;
- right to request a confirmation from us whether your personal data is or is not being processed;
- right to request information about the status of processing of your personal data;
- right to request information about the source from which we obtained your personal data for processing;
- right to request rectification, updating or completion of your data;
- right to restrict certain data processing activities, which means we store your personal data but do not use it for any other purpose. If you have obtained processing restriction, you will be informed before lifting the data processing restriction, if applicable;
- right to reject the use of your personal data for marketing purposes;
- right of portability (transfer) of the data you provided to us in relation to the specific purpose for which you provided us with this data; however, the portability of your personal data has to be possible according to art. 20 of the GDPR, or the portability will be denied by us as we cannot risk the unsafety of your personal data;
- right not to be subject to an automated decision making, having the opportunity to oppose an automatic decision process according to art. 22 from GDPR;
- right to be forgotten (deletion) of your personal data. We will evaluate your deletion request from the point of view of our internal laws and procedures, taking into account, if applicable, the existence of any existing instructions in place from our contractual partners and we will provide you with a written response within the legal term, which will not exceed one month (30 days term) from the receival date of the deletion request.
- right to have your data removed from the system as further described in the next section on revocation of consent and deregistration.
right to address the relevant Data Supervisory Authority from the country you access Pramra Global, you can access mediation services in order to settle any dispute, or at a competent court, if you believe that your rights regarding the processing of personal data have been breached.
The National Supervisory Authority for each country where Pramra Global platform operates:
Autorité de la protection des données – Gegevensbeschermingsautoriteit (APD-GBA)
Rue de la Presse 35 – Drukpersstraat 35
1000 Bruxelles – Brussel
Tel. +32 2 274 48 00
Fax +32 2 274 48 35
Website: https://www.autoriteprotectiondonnees.be/ – https://www.gegevensbeschermingsautoriteit.be/
Commission Nationale de l’Informatique et des Libertés – CNIL
3 Place de Fontenoy
TSA 80715 – 75334 Paris, Cedex 07
Tel. +33 1 53 73 22 22
Fax +33 1 53 73 22 00
Der Bundesbeauftragte für den Datenschutz und die Informationsfreiheit
Graurheindorfer Straße 153
Tel.: +49 228 997799 0
Fax: +49 228 997799 5550
The competence for complaints is split among different data protection supervisory authorities in Germany. Competent authorities can be identified according to the list provided under www.bfdi.bund.de/anschriften.
16. Revocation of your consent; deregistration; data retention
16.2. We may in any case keep the data for as long as we are required by applicable law or by our internal retention terms, including company law or tax law or otherwise, to keep transaction related information. We may hold on to some of your personal data for longer (typically for a period from six years to 10 years) if reasonably needed for legal, regulatory or tax reasons, deal with disputes, prevent fraud or abuse and/or enforce our terms and conditions. We will keep your information which we use only for newsletters or other marketing according to our internal Data Retention Policy, but mainly until you tell us to stop sending you such messages or your account is closed or, applicable to personal data of our partners, until our contract with you has otherwise ended.
16.3. In case no transaction has occurred between you and us prior to your revocation or request for deregistration, we will remove or anonymize your data from the system such that it cannot be accessed anymore.
17. Data security
17.2. All information you provide to us is stored on secure servers. Any payment transactions will be encrypted using SSL technology.
17.3. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to and from our Website or/or from our mobile App; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
17.4. We are not responsible for damages incurred which are outside our reasonable control, including malfunctions that could jeopardize the security of the servers on which the database containing personal data are hosted.
17.5. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website or mobile App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. You (only and exclusively) bear full responsibility for sharing your data with third parties.
18. Misuse of personal data
We do not assume any responsibility if you are misled by non-authorized third parties that present themselves as representatives of Pramra Global. Please inform us if you become aware of such behaviour by a third party.
19. Contact details for questions
20. Choice of Law and Jurisdiction (including regarding data protection authorities)
- laws and courts of/in Austria;
- laws and courts of/in Germany;
- laws and courts of/in France;
- laws and courts of/in Italy;
- laws and courts of/in Spain;
- laws and courts of/in Belgium.
Version: August / 2020