
PRIVACY POLICY
1 GENERAL PROVISIONS
- This document is an Annex to the Terms and Conditions. By using our services, you entrust your information to us. The present Privacy Policy is merely a means to help you understand what data and information is collected and why, as well as what we use it for. This data is very important to us, therefore we ask you to acquaint yourself with this document thoroughly, as it defines the rules and methods for the processing and protection of your personal data. This document also defines the rules for using “cookie” files.
- We hereby declare that we respect the rules for the protection of personal data as well as any and all legal regulations set out by the Law on Protection of Personal Data and Regulation (EU) 2016/679 of 27 April 2016 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, and repealing Directive 95/46/EC.
- A person whose personal data is processed has the right to contact us in order to obtain exhaustive information on how we use his personal data. We always try to provide clear information on the data we gather, how we use it, what purposes are they to serve and who we transfer them to, what protection of this data we ensure after transferring them to other entities, as well as provide information on the institutions that should be contacted in case of doubt.
- The website employs technical means such as: physical means of protection of personal data, hardware means of digital and telecommunications infrastructure, means of protection within the framework of programming tools and databases, as well as organisational means ensuring adequate protection of the personal data processed, especially protecting personal data from being shared with unauthorised third parties, being obtained by an unauthorised person and used for an unknown purpose, as well as from being accidentally or purposely altered, lost, damaged or destroyed.
- As set out by the rules defined in the Terms and Conditions and in the present document, we have exclusive access to the data. Access to personal data may also be granted to other entities through which payments are made, that collect, process, and store personal data in accordance with their own Terms and Conditions, as well as entities that are tasked with order processing. Access to personal data shall be granted to the above entities to the extent necessary and only such that will ensure the provision of the services.
- Personal data shall only be processed for those purposes to which you have given your consent by clicking the respective fields of the form found on the Website, or in another express way. The legal grounds for the processing of your personal data is the consent for the processing of data or the requirement to perform a service (e.g. ordering Goods) that you have ordered from us (pursuant to Article 6 Section 1 letters a and b of Regulation (EU) 2016/679 of 27 April 2016 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, and repealing Directive 95/46/EC (General Data Protection Regulation) – GDPR
2 RULES ON PRIVACY
- We take privacy seriously. We are distinguished by our respect for privacy and the fullest guaranteed convenience of using our services.
- We prize the trust that the Users place in us by entrusting us with their personal data for processing the orders. We always use personal data in an honest manner, acting so as to not betray that trust, and only to the extent necessary for carrying out the order, including its processing.
- The User has the right to obtain clear and full information on how we use his personal data and what purposes do we need it for. We always provide clear information on the data we collect, how and to whom we transfer them, as well as give information on the entities that are to be contacted in case you have doubts, questions, or comments.
- In case of doubt related to our use of the User’s personal data, we shall take immediate action in order to clear such doubt, answering all of the related questions in a full and exhaustive manner.
- We shall take any and all justified measures to protect the Users’ data from undue and uncontrolled use, as well as to protect it in a comprehensive manner.
- The data of your Data Controller is found in the “Contact Us” tab located on the website.
- The legal grounds for processing your personal data is Article 6 Section 1 letter b of the GDPR. Providing the data is not mandatory, but is necessary for us to take the appropriate actions preceding the conclusion and execution of a contract. We shall transfer your personal data to other entities entrusted with processing of personal data in our name and on our behalf. Your data shall be transferred pursuant to Article 6 Section 1 letter f of the GDPR, where the legitimate interest is the due performance of contracts/orders. Furthermore, we shall make your personal data available to other trading partners. The personal data collected shall be stored in the territory of the European Economic Area (“EEA”), but it may also be transferred to and processed in a country outside of this area. Every personal data transfer operation is carried out in accordance with the law in force. If the data is transferred outside of the EEA, we apply standard contractual clauses and the Privacy Shield as means of securing the data with respect to the countries which the European Commission has not determined as having an adequate level of data protection.
Your personal data associated with the conclusion and execution of the contract for the execution of contracts shall be processed during the period of execution, as well as for a period no longer than provided for by the provisions of law, including the provisions of the Polish Civil Code and the Accounting Law, i.e. for no longer than 10 years counting from the end of the calendar year in which the last of the contracts was executed.
- Your personal data processed for the conclusion and execution of future contracts shall be processed until objection.
- You have the right to: access your personal data and receive a copy of the personal data subject to processing; rectify data pertaining to you that is incorrect; demand the removal of your data (the right to be forgotten) should the circumstances set out by Article 17 of the GDPR occur; demand the limitation of data processing in cases indicated in Article 18 of the GDPR; file an objection against data processing in cases indicated in Article 21 of the GDPR, transfer the provided data processed in an automated manner.
- If you think that your personal data is being processed in violation of law, you may file a complaint with the supervisory body (Personal Data Protection Office, ul. Stawki 2, Warsaw, Poland). If you need additional information pertaining to personal data protection or wish to exercise your rights, contact us by post at our mailing address.
- We do our utmost to protect the information in our possession against unauthorised use, unauthorised modification, disclosure or destruction. In particular:
- We verify the methods of collecting, storing, and processing information, including the physical means of security, in order to protect the system from unauthorised access.
- We only grant access to personal data to those employees, contractors, and representatives who must have access to them. Moreover, under contract, they are obliged to maintain strict confidentiality, to enable us to check and verify how they fulfil the duties entrusted to them, and, should they not observe these requirements, they may suffer consequences.
- We shall respect all of the provisions and regulations in force pertaining to data protection, and shall cooperate with data protection authorities, as well as the authorised investigative authorities. Should provisions pertaining to data protection be absent, we shall act in accordance with the generally-accepted rules for data protection, the principles of social coexistence, and established customs.
- The exact method of protecting personal data is found in the Personal Data Protection Policy (ODO: Security Policy, Personal Data Protection Terms and Conditions, Instructions for the IT system management) For security reasons, due to the procedures described therein, it may only be viewed by state audit bodies.
- If you have any questions related to the manner in which we handle personal data, we invite you to contact us via the website from which the user has been redirected to the present Privacy Policy. The request for contact shall immediately be communicated to the appropriate, appointed person.
- The user always has the right to notify us if:
- he does not want to receive information or messages from us in any form;
- he wishes to receive a copy of his personal data;
- he wishes to rectify, update, or remove his personal data found in our registers;
- he wishes to report violations or inappropriate use or processing of his personal data.
- In order to enable us to respond to or take a stance on the provided information more easily, please provide your full name and further details.
3 SCOPE AND AIMS OF PERSONAL DATA COLLECTION
- We process the necessary personal data for the purposes of providing services and accounting, and only such purposes, i.e.:
- for placing orders,
- for concluding contracts, processing claims and processing withdrawals,
- for issuing VAT invoices or other kinds of receipts.
- for monitoring the traffic on our websites;
- for the collection of anonymous statistics, in order to determine how users utilise our website;
- for determining the number of anonymous users of our websites
- for checking what contents are displayed to our users often, as well as how often;
- checking how often users choose a given service or from the level of which service does the contact occur the most commonly;
- for examining newsletter and contact option subscriptions;
- for making use of the system personalised recommendations for e-commerce;
- for using the tool for both email communication and, in consequence, for phone communication as well;
- for integration with social media;
- for potential online payments.
- We collect, process, and store the following user data:
- full name,
- address of residence,
- mailing address (if different from the address of residence),
- tax identification number (NIP),
- email address,
- telephone number (cell, landline),
- birth date,
- information on the web browser used,
- other personal data voluntarily given to us.
- The provision of the above data is fully voluntary, but also indispensable for carrying out the services in full.
- The goals of collecting and processing or using the data by us are:
- direct marketing, archiving purposes of advertising campaigns;
- carrying out the duties imposed by the provisions of law by collecting information on undesired actions;
- We may transfer personal data to servers found outside of the user’s country of residence or to associated entities, third parties with headquarters in countries outside of the EEA (European Economic Area, i.e. the free trade zone and single market encompassing the Member States of the European Union and of the EFTA, European Free Trade Association) for the processing of the personal data by such entities in our name, in accordance with the provisions of the present Privacy Policy and the provisions of law in force, customs, as well as regulations related to data protection.
- Your personal data shall be stored for a period of time no longer than needed to ensure proper quality of service and, depending on the procedure or purpose of their collection, we store them for the duration of the service and afterwards for:
- carrying out the duties resulting from the provisions of law, as well as fiscal and accounting regulations;
- preventing abuses or crimes;
- statistical and archiving purposes.
- Marketing actions – for the duration of the contract, or for the period for which separate consent for processing such data is granted – until the end of the activities related to processing the transactions or until you file an objection against such processing or until you withdraw your consent.
- Sales-related and promotional activities – e.g. competitions, promotional campaigns – for the duration of such campaigns and their settlement.
- Operational activities – until the expiry of the duties imposed by the GDPR and the respective provisions of local law, in order to prove diligence in the processing of personal data
- for pursuing any and all claims associated with the contract executed;
- Considering that in many countries that this personal data is transferred to the level of personal data protection does not match that of the user’s country. The user’s personal data stored in another country may be accessed in accordance with the local laws, by, for example: courts, bodies responsible for law enforcement and national security, per the laws of that country. With the exception of lawful data disclosure requests, we undertake to require the entities processing personal data outside of the user’s country to take actions aiming to protect the data adequately to local legal regulations.
4 COOKIES POLICY
- We collect the information contained in browser cookies automatically in order to collect User data. Browser cookies are small pieces of text sent to the User’s browser then sent back by the browser on the instances of entering the website that follow. They are used mostly to maintain the session by generating and sending back a temporary identifier upon logging in. We use “session” cookies stored on the User’s terminal device until the User logs out, closes the web page or closes the browser, as well as “permanent” cookies stored on the User’s terminal device for a time specified in the cookies’ parameters or until removed by the User.
- Cookies adapt and optimise the website and its offer to the Users’ needs by actions such as creating view statistics and providing security. Cookies are also necessary in order to maintain the session after the user leaves the website.
- The Administrator processes the data contained in the cookies every time the website is visited for the following purposes:
- optimising the use of the website;
- identifying Clients as logged in at a given moment;
- adapting graphics, choice options and other contents of the website to the individual preferences of the Client;
- saving the data entered both automatically and manually into Order Forms or the login credentials provided by the visitor;
- collecting and analysing anonymous statistics presenting the manner of using the website in the admin panel and in Google Analytics
- creating remarketing lists based on information on the preferences, behaviour, and use of the Website by the interested parties, as well as collecting demographical data, then making these lists available in AdWords and Facebook Ads.
- creating data segments based on demographical information, interests, and preferences related to the choice of products/services viewed.
- using demographical data and data on interests in Analytics reports.
- The User may, using his web browser, block and delete the collection of cookies at any time.
- Blocking the possibility of cookie collection on the User’s device by the User may render using some of the website’s functionalities difficult or impossible; the User has every right to do it, but must be aware of the functional limitations.
- A User who does not want to use cookies for the above-described purposes may at any moment remove them manually. In order to become familiar with the detailed instructions for proceeding, it is necessary to visit the website of the maker of the User’s current web browser.
- More information on cookies is found in the Help menu of every web browser. Examples of web browsers using the above-described cookie files:
- Cookie settings Internet Explorer
- Cookie settings Chrome
- Cookie settings Firefox
- Cookie settings Opera
- Cookie settings Safari
- Cookies in Android
- Cookies in Blackberry
- Cookies in iOS (Safari)
- Cookies in Windows Phone
5 RIGHTS AND OBLIGATIONS
- We have the right, and, in cases defined by the law, also the statutory duty, to transfer chosen pieces of information or all information pertaining to personal data to public authorities or third parties that present such a request for information disclosure pursuant to the provisions of Polish law.
- The user has the right to access the contents of the personal data provided by him, to amend and complete this data at any time, and to demand that the data be removed from the databases or that it be no longer processed, without giving any reason for such a request. In order to exercise his rights, the User may at any time send an appropriate message to the email address or in another way to deliver/convey such a request.
- The processing of personal data belonging to individuals who are our customers is based on:
- the legitimate interest of the data controller (e.g. within the scope of database creation, analytical and profiling activities, including those related to the analysis of product use, direct marketing of own products, securing documentation for the purpose of defending against potential claims or for pursuing claims
- consent (including, in particular, the consent for email marketing or telemarketing)
- the execution of the concluded contract
- duties arising from the law (e.g. tax law or accounting laws).
- The processing of personal data of individuals being potential customers is based on:
- the legitimate interest of the data controller (e.g. within the scope of database creation, direct marketing of own products)
- consent (including in particular the consent for email marketing or telemarketing)
- The User’s demand for removal of the personal data or cessation of its processing may result in the complete impossibility or severe limitation of service provision.
- We deem the matters of profiling especially important and we indicate that:
- for the needs of profiling, we generally process data that was previously subjected to SSL encryption;
- for this end, we use typical data: email address, IP address, or cookies
- we carry out profiling in order to analyse or predict personal preferences or interests of the persons using our Websites or products or services and adapt the contents found on our Websites or products to those preferences
- we carry out profiling for marketing purposes, i.e. for adapting the marketing offer to the abovementioned preferences.
- We undertake to proceed in accordance with the provisions of law in force and the principles of social coexistence.
- Information on out-of-court examination of consumer disputes. Pursuant to the Law on Out-of-Court Consumer Dispute Settlement, the authorised entity is the Financial Ombudsman, whose web address is: www.rf.gov.pl.
6 BASIC SECURITY RULES
- Every user should take care of the safety of his own data and of that of his devices that serve the purpose of accessing the internet. Such a device should at all times have anti-virus software installed, with a regularly-updated database of definitions, types, and kinds of viruses, as well as a secure version of the web browser used and an active firewall. The User should verify whether the operating system and software present on the device have their newest, compatible updates installed, as attacks make use of the errors detected in the software installed.
- The access data for online services such as e.g. logins, passwords, PINs, electronic certificates etc. should be secured in a place inaccessible to others and impossible to break into from the online network level. They must not be disclosed or stored on the device in a form permitting unauthorised access and reading by persons not authorised to do it.
- Care must be taken when opening strange attachments or clicking links in emails that we did not expect to receive, e.g. from unknown senders or in the spam folder.
- It is advisable to activate in the browser anti-phishing filters, i.e. tools checking if the website being viewed is authentic and does not serve the purpose of extorting information, e.g. by pretending to be a person or an institution.
- The files should only be downloaded from trusted places, internet-based services, and websites. We advise against installing software from unverified sources, especially from unknown publishers of unverified reputation. This also regards mobile devices, such as e.g. smartphones or tablets.
- While using a wireless home Wi-Fi network, it is necessary to set a password that is secure and difficult to break; it should not be any pattern or string of characters that is easy to guess (such as e.g. the street name, the host’s name, his birth date etc.). It is also recommended to use the highest possible standards of Wi-Fi network encryption possible to run on the device used, such as e.g. WPA2.
7 USING SOCIAL MEDIA PLUGINS
- Our pages may feature plugins of facebook.com, Twitter, and other social networks. The services associated therewith are provided, respectively, by Facebook Inc. and Twitter Inc.
- Facebook is run by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA Facebook. In order to see the Facebook plugins, go to: https://developers.facebook.com/docs/plugins
- Twitter is run by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. In order to see Twitter’s plugins, go to: https://dev.twitter.com/web/tweet-button
- The plug-in only gives the provider information on which of our webpages have you accessed and at what time. If the user is logged into his Facebook or Twitter account while viewing our website or being on it, the provider is able to connect your interests, information preferences, and other data obtained due to you clicking the ‘Like’ button, leaving a comment or entering the name of a profile in the search box. Such information will also be transferred by the browser directly to the provider.
- More detailed information on the collection and use of data by Facebook and Twitter, as well as on privacy protection, may be found on the following websites:
- Data protection / privacy-related advice from Facebook: http://www.facebook.com/policy.php
- Data protection / privacy-related advice from Twitter: https://twitter.com/privacy
- In order to prevent Facebook or Twitter from taking note of the visit on our website on a given user account, you must log out of your account before you begin browsing our web pages.
NOTE ON THE SALES TERMS AND CONDITIONS COPYRIGHTS
The holder of all of the legal economic copyrights for the model of the present Sales Terms and Conditions is Kancelaria Prawna LEGATO, which has granted to this store a non-exclusive and inalienable right to use these Terms and Conditions for purposes related to its online trade activity, and extends the legal protection onto the said document for the duration of the contract. Copying and distributing the model of the present document without the consent of Kancelaria Prawna LEGATO is prohibited and may be subject both to penal and civil liability. Online sellers may learn more about the possibility of using the model cookies and privacy policy on the following website: http://www.kancelaria-legato.pl/
