PRIVACY POLICY

1. BASIC TERMS
1.1. Company or Personal Data Controller – UAB “Novtra”, a private limited liability company established and operating in accordance with the laws of the Republic of Lithuania, company code
306378020, registered office at Sveikatos g. 29, Struikų k., LT-75110 Šilalės r.
1.2. Customer or Data Subject – a natural person – a customer of the Company (including website
visitors) whose personal data is collected by the Company.
1.3. Online store – the Company’s online store at https://keluvo.com.
1.4. Services – all services provided by the Company.
1.5. Personal data – any information related to a natural person – the Data Subject, whose
identity is known or can be directly or indirectly determined using such data
as a personal identification number, one or more factors specific to the physical, physiological, psychological, economic,
cultural, or social identity of that natural person.
1.6. Processing of personal data – any action performed with personal data: collection,
recording, accumulation, storage, classification, grouping, combination, modification (addition or
correction), provision, publication, use, logical and/or arithmetic operations, search,
dissemination, destruction, or any other action or set of actions.
1.7. Partner – a legal entity that provides services to the Company related to the Company’s activities
or sells goods to it, or carries out joint projects with the Company, including, but
limited to marketing campaigns, joint sales campaigns, loyalty programs, etc.,
in the media, on websites, in the Online Store, in retail
stores, in retail chains, etc.
1.8. Cookie – a small piece of text information that is automatically created
when browsing a website and is stored on the visitor’s computer or other device.
1.9. Direct marketing – activities aimed at offering goods or services to individuals by mail, telephone, or other direct means
and/or to ask for their opinion on the goods or services offered.
1.10. Privacy Policy – means this document, which sets out the principles and rules for the processing of Personal Data
when using the services of the Online Store.
1.11. Account – the main data used by the Customer to log in to the Online Store, consisting of
an email address and a password.
1.12. Password – a unique combination of numbers, letters, or numbers and letters or other symbols created by the Customer
that, when entered, allows the Customer to log in to the Online Store.

2. GENERAL PROVISIONS
2.1. The Customer grants the Company the right to perform all Personal Data processing activities within the scope and for the purposes set forth in this
Privacy Policy.
2.2. Personal Data is processed in accordance with the Personal Data Protection Law of the Republic of Lithuania
and other legal acts regulating the processing and protection of Personal Data
and this Privacy Policy.
2.3. Personal Data is processed by the Company in accordance with the following principles:
2.3.1. Personal Data is collected for specified and legitimate purposes;
2.3.2. Personal data is processed accurately, fairly, and lawfully;
2.3.3. Personal data is adequate and limited to what is necessary for the purposes for which it is collected and further processed;
2.3.4. Personal data is kept up to date;
2.3.5. Personal data shall be stored in a form that allows the identity of the data subject to be determined
for no longer than is necessary for the purposes for which the data was collected and processed.
2.3.6. All information about personal data is confidential;
2.3.7. The Customer’s personal data and personal information will not be used for unlawful purposes.
2.4. It is assumed that by purchasing from the Online Store, the Customer has read and agrees to the current version of the
Privacy Policy. If the Customer does not agree with any part of the Privacy Policy or
the Privacy Policy, the Customer must not place an order or purchase goods in the Online Store.

2.5. The Privacy Policy is available in the Online Store and can be printed at any time.
The Privacy Policy may be changed, supplemented, or updated at the Company’s discretion. The new version of the Privacy
Policy shall be published in the Online Store.
2.6. The Customer may place an order in the Online Store without registering or through their Account
after registering in the Online Store.
2.7. During the initial registration in the Online Store via the Account, the Customer must provide
their email address, create a secure Password, and provide accurate Personal Data
to the Online Store. The Customer is responsible for their accuracy. After creating an Account, the Customer is assigned an
identification code.
2.8. When using the Services and making purchases in the Online Store, the Customer must always
provide accurate personal data to the Online Store and is responsible for its accuracy.
2.9. The Customer has the right to change and supplement the personal data in the Account at any time or contact
the Online Store with a request to delete the Account.
2.10. The Customer must not disclose the Password to third parties and must keep it safe, otherwise all
related responsibility shall lie with the Customer.

3. COLLECTION, USE, CORRECTION, AND STORAGE OF PERSONAL DATA
3.1. The Company respects the right to privacy of each Customer. Customer Personal Data (i.e., name,
surname, email address, telephone number, delivery address for goods/services,
age/year of birth, payment details for goods/services (bank account number, payment
method, etc.), purchase history, and, with the Customer’s consent, age, gender, date of birth,
place of residence) are collected and processed for the following purposes:
3.1.1. For the purpose of e-commerce. The following Personal Data is processed: first name, last name, email
, telephone number, delivery address for goods/services, age/year of birth, IP
address, payment details for goods/services. The storage period for personal data used for e-commerce
purposes is 5 (five) years from the last login to the E-shop
store.
3.1.2. For direct marketing purposes. The following personal data is processed: first name, last name, telephone
number, email address, address, age, gender, date of birth, place of residence.
used for direct marketing purposes is 5 (five) years from the
date of the last login to the Online Store.
3.2. The Customer may give consent for the processing of their Personal Data (first name, last name, telephone number,
e-mail address, address, age, gender, date of birth, place of residence) for
direct marketing purposes. If the Customer has given consent to the processing of their data for direct marketing purposes
as well as to receive direct marketing messages, the Customer later changes their mind and informs
the Company of this, the Company will no longer process their Personal Data for direct marketing purposes and will not send
the Customer any electronic news, except for information related to the Customer’s order.
3.3. The Customer has the right to revoke their consent to the Company processing their
Personal Data for Direct Marketing purposes at any time by submitting a relevant notification
to the Company by email to info@keluvo.com and clearly stating that they revoke their
consent to the use of their Personal Data for Direct Marketing purposes and that they do not wish to receive any
Direct Marketing communications.
3.4. The Customer also has the option to waive their right to object to the processing of their Personal Data
for direct marketing purposes by clicking on the relevant link in
each email sent.
3.5. As a Data Subject, the Customer has the following rights in relation to the processing of the Customer’s
Personal Data:
3.5.1. to receive information from the Company about the processing of the Customer’s Personal Data, to familiarize themselves with their
Personal Data and how it is processed;
3.5.2. to receive information from the Company about the sources and types of the Customer’s Personal Data collected, the purposes for which
purpose it is processed, to which data recipients it is provided and has been provided to at least during the last 1 (one)
year;
3.5.3. to request the correction, destruction of the Customer’s Personal Data or the suspension, except for storage,
processing of their personal data when the personal data is processed in violation of the provisions of the
Personal Data Protection Law of the Republic of Lithuania and other laws.
3.6. In exercising their rights, the Customer must present their passport, identity card, or driver’s
license. The Company shall provide the Data Subject with information about the Data Subject’s Personal Data being processed
once a year free of charge. The Customer may exercise their rights provided for in clause 3.5
by sending an email to info@keluvo.com. The Company has the right to correct, change, delete
Personal Data or suspend the processing of Personal Data only after identifying the Customer who made the request.
3.7. The Customer’s Personal Data shall not be disclosed to third parties, except in the following cases:
3.7.1. When the Customer’s consent has been obtained, as specified in this Privacy Policy;
3.7.2. Personal data is provided for e-commerce purposes to Partners who provide the Company with
services related to the Company’s activities;
3.7.3. To competent authorities in cases provided for by the laws and regulations of the Republic of Lithuania.
3.8. The Customer is aware of their right to object to the processing of their Personal Data for Direct
Marketing purposes, i.e. the Customer has the right to object immediately or at a later date.
3.9. The Customer agrees that their Personal Data may be transferred to Partners when fulfilling the Customer’s
order placed in the Online Store, as well as when the Company provides Services to the Customer, and
to the Company’s Partners, as specified in clause 3.7.
3.10. If the Customer does not agree with the Privacy Policy, the Customer will not be able to use the services of the Online
Store.
3.11. The Company implements organizational and technical measures to protect Personal
Data from accidental or unlawful destruction, alteration, disclosure, as well as from any other
unlawful processing.
3.12. The Customer agrees that in cases where it is necessary in accordance with the instructions of the competent authorities and/or
the Customer’s Personal Data may have been used in illegal activities, or there are reasonable suspicions
of identity theft, for which the competent law enforcement authorities are conducting a pre-trial
investigation, or there are other legitimate grounds or purposes, his/her Personal Data will be stored on the Company’s
servers for longer than specified in this Privacy Policy.
3.13. Upon receiving an instruction or request from the Data Subject regarding the processing of Personal Data,
the Company shall provide the Customer with a response, either granting the request/instruction or refusing to do so with justification
no later than within 30 (thirty) calendar days from the date of the Data Subject’s request.
If the Data Subject so wishes, the response shall be provided in writing.
3.14. In order for the Company to be able to offer the Customer full-fledged services in the Online Store,
with the Customer’s consent, information (cookies) is stored on the Customer’s computer (device), which
is used to identify the Customer as a previous user of the Online Store, to collect
statistics on visits to the Online Store, and information about the shopping cart. The Customer may at any time
view which cookies are stored and may delete some or all of the stored cookies.
3.15. To learn more about cookies, such as how to manage or delete them, please
visit www.allaboutcookies.org.

4. OTHER PROVISIONS
4.1. The Company has the right to change or supplement the Privacy Policy in whole or in part. Additions or changes to the Privacy Policy
shall take effect on the date of their publication.
4.2. If you have any questions, please contact us at: info@keluvo.com