Privacy Policy

This notice applies to any online and mobile website, application and digital
service (“Services”) of the company GUZANA CONCEPT SRL (“MAKFERO”,
“we”, “us” or “our”).

It also describes your data protection rights, including a right to object to some of the
processing which GUZANA CONCEPT carries out (e.g. direct marketing). More
information about your rights, and how to exercise them, is set out in the “What rights
do I have ?” section.
You can also learn about cookies and similar technology in this notice.

  1. What information do we collect?
    The following categories of personal data will be collected about you in connection
    with your interaction with us and use of our Services including, but not limited to,
    when you purchase products on our Services, you complete forms on our Services,
    submit user-generated reviews or ratings, and engage in any social media functions
    on our Services.
    Information you give us
    o personal identification information such as your name, date of birth and
    gender;
    o contact information such as email address and telephone number;
    o demographic information: such as postal address;
    o financial information: such as credit/debit card numbers;
    o your purchase history;
    o if you have completed a survey or entered a competition with us;
    o if you contact us by phone, email or otherwise, we will keep a record of
    that correspondence; and
    o your marketing preferences, including any consents you have given us
    when you subscribe to our newsletter or set up an online account.

Information we collect automatically
o information related to the browser, device or operating system you use
to access our Services;
o your IP address, the website you came from, information on actions
taken on our Services including but not limited to pages viewed, dated
and times of visits, time spent on each page, products viewed, clicked
on, added to your basket and purchased; 
Information we receive from third parties
Sometimes, we receive personal data about you from third parties when you engage
with our Services through social media, or other sites or applications, those sites will
share personal data with us including, but not limited to:

the content you have viewed or interacted with;
about adverts within the content which you have been shown or clicked on;
your IP address, registered beacons or GPS (geolocation) signals you have
received;

publically available information; and
non-personal information used to supplement existing information, such as
demographics and affluence metrics (e.g. social-demographic groupings
through matching postcodes).
The privacy notices for these sites and applications will contain more detail about this
and how to change your privacy settings on those sites and applications. 

  1. How do we use this information, and what is the legal basis for this use

    We process your personal data for the following purposes:
    To fulfill a contract, or take steps linked to a contract including fulfilling any
    orders your place. This includes :
    o processing your order, registration for the Services, or entry to a
    competition;
    o providing the Services, to communicate with you about them or your
    account with us;
    o communicating with you (including by email and SMS) and providing
    our customer services;
    o verifying your identity; and sending you information about changes to
    our terms or policies.

To conduct our business and pursue our legitimate interests, in particular :

  • we will use your personal data to provide products and Services you have
    requested, and respond to any comments or complaints you may send us;
  • we monitor the use of our Services and use your personal data to help us,
    monitor, improve and protect our products, content, Services, and websites,
    both online and offline;
    -we use your personal data to personalize our products and Services for you;
    To prevent, investigate and/or report fraud, misrepresentation, security
    incidents or crime, in accordance with applicable law;
  • we use information you provide to investigate any complaints received from
    you or from others, about our website or our products or services;
  • we will use data in connection with legal claims, compliance, regulatory and
    investigative purposes as necessary (including disclosure of such information
    in connection with legal process or litigation); and
    Where you give us your consent, we will use your personal data :
  • to send you newsletters and other promotional material about our Services
    and to use technologies to check if these have been received and opened to
    help make our communications relevant to you;
  • to place cookies and use similar tracking technologies (as set out in the
    “Cookies” section and the information provided to you when those

technologies are used) to personalize content and advertising for you and to
make our content function better;

  • to invite you to take part in market research (where consent is required); and
    on other occasions where we ask you for consent, we will use the data for the
    purpose which we explain at that time.

For purposes which are required by law : in response to requests by government or
law enforcement authorities conducting an investigation.

  1. Relying on our legitimate interests
    We have carried out balancing tests for all the data processing we carry out on the
    basis of our legitimate interests, which we have described above. You can obtain
    information on any of our balancing tests by contacting us using the details set out
    below.
  2. Who will we share this data with, where and when?
    With your consent (where required), we share your personal data with trusted third-
    party service providers, suppliers, affiliates, divisions, partners, sponsors, agents and
    representatives we have engaged to perform business-related functions on our
    behalf. For example, to:
    conduct research and analytics;
    create content;
    provide customer support services;
    conduct or support marketing;
    fulfill orders;
    handle payments;
    host Services;
    administer contests;
    maintain databases.
    In all cases, the third party is acting on MAKFERO express instructions and in
    accordance with this Policy, confidentiality, and levels of security.
    Without your consent, we share your personal data:
    with third-party platforms such as Facebook or Google to send you targeted
    advertisements on our behalf;
    in response to legal process, for example, in response to a court order or a
    subpoena, law enforcement or government agency’s request;
    with third parties, if this will help us to enforce our policies and terms of use, to
    check for potential illegal activity (such as copyright infringement or fraud) or
    to protect the safety of other users of the Services; and
    if we, or one of our business units, undergoes a business transition, like a
    merger, acquisition by another company, or sale of all or part of our assets.

We operate globally, so we do need to transfer your personal data internationally. In
particular, your personal data will be transferred to and processed in Australia,
Canada, Chile, European Economic Area, Hong Kong, Singapore, Taiwan, and the
United States.
Where information is transferred outside the EEA, and where this is to a stakeholder
or vendor in a country that is not subject to an adequacy decision by the EU
Commission, data is adequately protected by EU Commission approved standard
contractual clauses, an appropriate Privacy Shield certification or a vendor’s
Processor Binding Corporate Rules. 

  1.  How long will you retain my data?
    Where we process personal data for marketing purposes or with your consent, we
    process the data until you ask us to stop and for a short period after this (to allow us
    to implement your requests). We also keep a record of the fact that you have asked
    us not to send you direct marketing or to process your data indefinitely so that we
    can respect your request in future.
    Where we process personal data in connection with performing a contract or for a
    competition, we keep the data for 5 years.
    Where we process registration data, excluding in the circumstances outlined above,
    we retain your data for 5 years.
  2. What rights do I have?
    You have the right to ask us for a copy of your personal data; to correct, delete or
    restrict (stop any active) processing of your personal data; and to obtain the personal
    data you provide to us for a contract or with your consent in a structured, machine-
    readable format, and to ask us to share (port) this data to another controller.
    You can object to the processing of your personal data in some circumstances (in
    particular, where we don’t have to process the data to meet a contractual or another
    legal requirement, or where we are using the data for direct marketing).
    These rights may be limited, for example, if fulfilling your request would reveal
    personal data about another person, where they would infringe the rights of a third
    party (including our rights) or if you ask us to delete information which we are
    required by law to keep or have compelling legitimate interests in keeping. We will
    inform you of the relevant exemptions we rely upon when responding to any request
    you make.
    To exercise any of these rights, or to obtain other information, such as a copy of a
    legitimate interest balancing test, you can get in touch with us using the details set
    out below. If you have unresolved concerns, you have the right to complain to an EU
    data protection authority where you live, work or where you believe a breach may
    have occurred.

Where we require your personal data to comply with legal or contractual obligations,
then provision of such data is mandatory: if such data is not provided, then we will
not be able to manage our contractual relationship with you or to meet obligations
placed on us.
Withdrawing consent or otherwise objecting to direct marketing
Wherever we rely on your consent, you will always be able to withdraw that consent,
although we may have other legal grounds for processing your data for other
purposes, such as those set out above. In some cases, we are able to send you
direct marketing without your consent, where we rely on our legitimate interests. 
You have an absolute right to opt-out of direct marketing we carry out for direct
marketing, at any time. You can do this by clicking on the unsubscribe link at the
bottom of our emails, or by contacting us using the details set out below.

  1. Security measures
    We have put in place physical, electronic, and managerial procedures designed to
    help prevent unauthorized access, to maintain data security, and to use correctly the
    personal data we collect online. These safeguards vary based on the sensitivity of
    the personal data that we collect and store.
    Although we take appropriate measures to safeguard against unauthorized
    disclosures of personal data, we cannot assure you that your personal data will never
    be disclosed, altered or destroyed in a manner that is inconsistent with this privacy
    notice.
  2. Children’s Privacy.
    Our Services do not target and are not intended to attract children under the age of
  3. We do not knowingly solicit personal data from children under the age of 18 or
    send them requests for personal information.
  4. Cookies.
    When you visit the Services we may store some information (commonly known as a
    “cookie” or similar technologies) on your device. Cookies are pieces of information
    that a website transfers to your hard drive to store and sometimes track information
    about you. Cookies are specific to the server that created them and cannot be
    accessed by other servers, which means that they cannot be used to track your
    movements around the web.
    Cookies can be categorized in accordance with the categories found in the ICC UK
    Cookie guide as set out below:
    strictly necessary cookies – These cookies are essential in order to enable you
    to move around a website and use its features and enable services you have
    specifically asked for. Consent is not generally required for these cookies;

performance cookies – these collect information about how visitors use a
website, for example, by recording which pages users go to most often
(usually on an anonymous basis);
functionality cookies – These cookies allow a website to remember the
choices a user makes, such as a user name or language preference; and
targeting or advertising cookies – these collect information about a user’s
browsing habits and are usually placed by advertising networks with the
website operator’s permission.
Cookies can also be categorized in accordance with how long they are saved on your
device. “Session cookies” are short-term cookies that are only saved on the
computer’s memory for the duration of a user’s visit to the website, whereas
“persistent cookies” remain saved in the computer’s memory for a set period of time,
even after the browser session has ended.
How to manage & remove cookies?
If you are using our Services via a browser you can change your cookie preferences
and withdraw your consent at any time using the Cookie Preferences Centre.  
You can find more detail about the third parties which place cookies on our
Services here.
The Help menu on the menu bar of most browsers also tells you how to prevent your
browser from accepting new cookies, how to delete old cookies, how to have the
browser notify you when you receive a new cookie and how to disable cookies
altogether.
If you are using our Services via an application, then you can change your consent
by following the relevant application’s directions. In addition, the operating system for
your device provides instructions on how to prevent tailored advertising and how to
reset your device’s advertising identifier.  

  1. Who is the data controller?
    The data controller for your information is GUZANA CONCEPT SRL which you have
    a relationship with or which manages the Site you have visited. Please find our
    contact details below.
  2. How do I get in touch with you?
    We hope that we can satisfy queries you may have about the way we process your
    data. If you have any concerns about how we process your data or would like to opt-
    out of direct marketing, you can get in touch at
    By Email: info@makfero.com 
  3. Changes to this Privacy Notice.

From time to time, we may update this notice. We will notify you about any upcoming
material changes by either sending you an email to the email address you most
recently provided to us or by prominently posting a notice on our Services. We
encourage you to periodically check back and review this notice so that you know
what personal data we collect, how we use it, and with whom we share it.