PRIVACY POLICY – TABLE OF CONTENTS:
- GENERAL PROVISIONS
- GROUNDS FOR DATA PROCESSING
- PURPOSE, LEGAL BASIS, PERIOD AND SCOPE OF DATA PROCESSING IN THE ONLINE STORE
- DATA RECIPIENTS IN THE ONLINE STORE
- PROFILING IN THE ONLINE STORE
- RIGHTS OF THE DATA SUBJECT
- COOKIES IN THE ONLINE STORE, OPERATIONAL DATA AND ANALYTICS
- FINAL PROVISIONS
1. Privacy Policy – GENERAL PROVISIONS
1.1. This privacy policy of the Online Store is for informational purposes, which means that it does not constitute a source of obligations for the Service Recipients or Customers of the Online Store. The privacy policy primarily contains rules regarding the processing of personal data by the Controller in the Online Store. These include the grounds, purposes and scope of personal data processing, as well as the rights of persons whose data are concerned. In addition, it contains information on the use of cookies and analytical tools in the Online Store.
1.2. The controller of personal data collected via the Online Store is WIESŁAW ROZYNEK, conducting business under the name PPHU “EUROWOLLE“ WIESŁAW ROZYNEK. The entity is entered in the Central Registration and Information on Business of the Republic of Poland kept by the minister competent for economic affairs. The company has: business address: ul. Wrocławska 5, 58-309 Wałbrzych and mailing address: ul. Wałbrzyska 38, 58-160 Świebodzice, NIP 8860020064, REGON 890022736, e-mail address: sklep@eurowolle.pl, telephone number: 74/854-74-72 – hereinafter referred to as the “Controller”, who is also the Service Provider of the Online Store and the Seller.
1.3. Personal data in the Online Store are processed by the Controller in accordance with applicable legal provisions. In particular, in accordance with the regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 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) – hereinafter referred to as the “GDPR” or the “GDPR Regulation”. Official text of the GDPR Regulation: http://eur-lex.europa.eu/legal-content/PL/TXT/?uri=CELEX%3A32016R0679
1.4. Use of the Online Store, including making purchases, is voluntary. Likewise, providing personal data by the Service Recipient or Customer using the Online Store is voluntary. However, there are two exceptions:
(1) entering into agreements with the Controller
Failure to provide personal data necessary to conclude and perform the Sales Agreement or an agreement for the provision of an Electronic Service with the Controller – in cases and to the extent indicated on the Online Store website and in the Online Store Terms and Conditions and this privacy policy – results in the inability to conclude such an agreement. In such a case, providing personal data in accordance with the rules set out in the privacy policy is a contractual requirement, and if the data subject wishes to conclude a given agreement with the Controller, they are obliged to provide the required data. Each time, the scope of data required to conclude an agreement is indicated in advance on the Online Store website and in the Online Store Terms and Conditions;
(2) the Controller’s statutory obligations
Providing personal data is a statutory requirement resulting from generally applicable provisions of law that impose on the Controller an obligation to process personal data. This applies to situations such as, for example, data processing for the purpose of keeping tax or accounting records, and failure to provide such data will prevent the Controller from fulfilling those obligations.
1.5. The Controller takes special care to protect the interests of persons whose personal data are processed. In particular, the Controller is responsible for and ensures that the data collected by him, as referred to in this privacy policy, are:
(1) processed lawfully;
(2) collected for specified, lawful purposes and not further processed in a manner incompatible with those purposes;
(3) substantively correct and adequate in relation to the purposes for which they are processed;
(4) stored in a form which permits identification of the data subjects for no longer than is necessary for the purposes of the processing, and
(5) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
1.6. Taking into account the nature, scope, context and purposes of the processing and the risk of infringement of the rights or freedoms of natural persons of varying likelihood and severity, the Controller implements appropriate technical and organisational measures to ensure that processing is performed in accordance with this Regulation and to be able to demonstrate this. These measures are reviewed and updated where necessary. In addition, the Controller applies technical measures to prevent unauthorised persons from obtaining and modifying personal data transmitted electronically.
1.7. Any words, expressions and acronyms used in the “privacy policy” section and beginning with a capital letter (e.g., Seller, Online Store, Electronic Service) should be understood in accordance with their definition. These definitions are included in the Online Store Terms and Conditions available on the Online Store website.
2. GROUNDS FOR DATA PROCESSING – privacy policy at eurowolle
2.1. The Controller is entitled to process personal data in cases where – and to the extent that – at least one of the following conditions is met:
(1) the data subject has given consent to the processing of their personal data for one or more specific purposes;
(2) processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract;
(3) the data and their processing are necessary for compliance with a legal obligation to which the Controller is subject;
(4) processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party. Exceptions apply in situations where the interests or fundamental rights and freedoms of the data subject, requiring protection of personal data, override those interests, in particular where the data subject is a child.
2.2. Each instance of personal data processing by the Controller requires at least one of the grounds indicated in item 2.1 of this privacy policy. The specific grounds for processing personal data of Service Recipients and Customers of the Online Store by the Controller are indicated in the next section of the privacy policy, with reference to the particular purpose of processing personal data by the Controller.
3. PURPOSE, LEGAL BASIS AND PERIOD OF DATA PROCESSING IN THE ONLINE STORE
3.1. Each time, the purpose, legal basis and period, as well as the recipients of personal data processed by the Controller, result from the actions taken by a given Service Recipient or Customer in the Online Store or by the Controller. For example, if a Customer decides to make purchases in the Online Store and chooses personal collection of the purchased Product instead of courier delivery. In such a case, as provided for in the privacy policy, their personal data will be processed for the purpose of performing the concluded Sales Agreement, but will no longer be made available to the carrier carrying out shipments on behalf of the Controller.
3.2. The Controller may process personal data within the Online Store for the following purposes, on the legal bases and for the periods indicated in the table below:
Purpose of data processing | Legal basis for data processing | Data retention period |
Performance of the Sales Agreement or an agreement for the provision of an Electronic Service, or taking steps at the request of the data subject prior to entering into the above agreements | Article 6(1)(b) of the GDPR Regulation (performance of a contract) – processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract | Data are stored for the period necessary to perform, terminate, or otherwise expire the concluded Sales Agreement or an agreement for the provision of an Electronic Service. |
Direct marketing | Article 6(1)(f) of the GDPR Regulation (legitimate interests of the controller) – processing is necessary for the purposes of the legitimate interests pursued by the Controller – consisting in safeguarding the interests and good reputation of the Controller and its Online Store, and striving to sell Products | Data are stored for the period during which the legitimate interest pursued by the Controller exists, but no longer than for the period of limitation of the Controller’s claims against the data subject arising from the Controller’s business activity. The limitation period is defined by law, in particular the Civil Code (the basic limitation period for claims related to business activity is three years, and for the Sales Agreement two years). The Controller may not process data for direct marketing purposes if the data subject has effectively objected to such processing. |
Marketing | Article 6(1)(a) of the GDPR Regulation (consent) – the data subject has consented to the processing of their personal data for marketing purposes by the Controller | Data are stored until the data subject withdraws consent for further processing of their data for this purpose. |
Customer expressing an opinion about the concluded Sales Agreement | Article 6(1)(a) of the GDPR Regulation – the data subject has consented to the processing of their personal data for the purpose of expressing an opinion | Data are stored until the data subject withdraws consent for further processing of their data for this purpose. |
Keeping accounting records | Article 6(1)(c) of the GDPR Regulation in conjunction with Article 74(2) of the Accounting Act, i.e., of 30 January 2018 (Journal of Laws of 2018, item 395) – processing is necessary for compliance with a legal obligation to which the Controller is subject | Data are stored for the period required by law obliging the Controller to keep accounting records (5 years, counted from the beginning of the year following the financial year to which the data relate). |
Establishing, pursuing or defending claims that may be raised by the Controller or that may be raised against the Controller | Article 6(1)(f) of the GDPR Regulation (legitimate interests of the controller) – processing is necessary for the purposes of the legitimate interests pursued by the Controller – consisting in establishing, pursuing or defending claims, that may be raised by the Controller or that may be raised against the Controller | Data are stored for the period during which the legitimate interest pursued by the Controller exists, but no longer than for the period of limitation of claims that may be raised against the Controller (the basic limitation period for claims against the Controller is six years). |
Using the Online Store website and ensuring its proper operation | Article 6(1)(f) of the GDPR Regulation (legitimate interests of the controller) – processing is necessary for the purposes of the legitimate interests pursued by the Controller – consisting in operating and maintaining the Online Store website | Data are stored for the period during which the legitimate interest pursued by the Controller exists, but no longer than for the period of limitation of the Controller’s claims against the data subject arising from the Controller’s business activity. The limitation period is defined by law, in particular the Civil Code (the basic limitation period for claims related to business activity is three years, and for the Sales Agreement two years). |
Keeping statistics and analysing traffic in the Online Store | Article 6(1)(f) of the GDPR Regulation (legitimate interests of the controller) – processing is necessary for the purposes of the legitimate interests pursued by the Controller – consisting in keeping statistics and analysing traffic in the Online Store in order to improve the functioning of the Online Store and increase sales of Products | Data are stored for the period during which the legitimate interest pursued by the Controller exists, but no longer than for the period of limitation of the Controller’s claims against the data subject arising from the Controller’s business activity. The limitation period is defined by law, in particular the Civil Code (the basic limitation period for claims related to business activity is three years, and for the Sales Agreement two years). |
4. DATA RECIPIENTS IN THE ONLINE STORE
4.1. For the proper functioning of the Online Store, including the performance of concluded Sales Agreements, it is necessary for the Controller to use the services of external entities. This applies, for example, to the software provider, courier, or payment service providers. The Controller uses only the services of such processors who provide sufficient guarantees of implementing appropriate technical and organisational measures so that the processing meets the requirements of the GDPR Regulation and protects the rights of data subjects.
4.2. Personal data may be transferred by the Controller to a third country, while the Controller ensures that in such a case the transfer will take place to a country ensuring an adequate level of protection – in accordance with the GDPR Regulation. The Controller also ensures that the data subject has the opportunity to obtain a copy of their data. The Controller transfers collected personal data only where and to the extent necessary to achieve the given purpose of processing in accordance with this privacy policy.
4.3. Personal data of Service Recipients and Customers of the Online Store may be transferred to the following recipients or categories of recipients:
carriers / freight forwarders / courier brokers – in the case of a Customer who uses postal or courier delivery of a Product in the Online Store, the Controller makes the collected personal data of the Customer available to the selected carrier, freight forwarder or intermediary carrying out shipments on behalf of the Controller to the extent necessary to deliver the Product to the Customer.
entities handling electronic or card payments – in the case of a Customer who uses electronic payments or a payment card in the Online Store, the Controller makes the collected personal data of the Customer available to the selected entity handling the above payments in the Online Store on behalf of the Controller to the extent necessary to process the payment made by the Customer.
service providers supplying the Controller with technical, IT and organisational solutions enabling the Controller to conduct business activity, including the Online Store and the Electronic Services provided through it. In particular, this applies to the provider of computer software for operating the Online Store, the e-mail and hosting provider, and the provider of software for company management and technical support to the Controller. The Controller makes the collected personal data of the Customer available to the selected supplier acting on its behalf only where and to the extent necessary to achieve the given purpose of data processing in accordance with this privacy policy.
entities providing accounting, legal, as well as advisory services, providing the Controller with accounting, legal or advisory support (in particular, an accounting office, a law firm or a debt collection company). The Controller makes the collected personal data of the Customer available to the selected supplier acting on its behalf only where and to the extent necessary to achieve the given purpose of data processing in accordance with this privacy policy.
providers of social plugins, scripts and other similar tools placed on the Online Store website that enable the browser of a person visiting the Online Store website to retrieve content from the providers of the aforementioned plugins (e.g., logging in using login data for a social networking service) and to transfer to those providers personal data of the visiting person for this purpose, including:
Meta Platforms Ireland Ltd. – the Controller uses social plugins of Facebook on the Online Store website (e.g., the Like button, Share button or logging in using Facebook login details). Therefore, in this connection, it collects and shares the personal data of the Service Recipient using the Online Store website with Meta Platforms Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland) to the extent and in accordance with the privacy rules available here: https://www.facebook.com/about/privacy/. These data include information about activities on the Online Store website, including information about the device, visited websites, purchases, displayed ads and the manner of using services. In addition, the data are transferred regardless of whether the Service Recipient has a Facebook account and whether they are logged in to Facebook.
5. PROFILING IN THE ONLINE STORE
5.1. The GDPR Regulation imposes on the Controller an obligation to inform about automated decision-making, including profiling, as referred to in Article 22(1) and (4) of the GDPR Regulation. This applies – at least in those cases – to meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject. With this in mind, the Controller provides in this section of the privacy policy information regarding possible profiling.
5.2. The Controller may use profiling in the Online Store for direct marketing purposes. Decisions made on this basis by the Controller do not concern the conclusion or refusal to conclude a Sales Agreement, nor the possibility of using Electronic Services in the Online Store. The result of using profiling in the Online Store may be, for example, granting a discount to a given person, sending them a discount code, reminding them about unfinished purchases, as well as sending a product proposal that may match that person’s interests or preferences. In addition, it may be possible to offer better terms compared to the standard offer of the Online Store. Despite profiling, it is the person who freely decides whether they want to use the discount or better terms received in this way and make a purchase in the Online Store.
5.3. Profiling in the Online Store consists in an automated analysis or prediction of a given person’s behaviour on the Online Store website. It takes place, for example, by adding a specific Product to the cart, browsing the page of a specific Product in the Online Store, or by analysing the previous purchase history in the Online Store. The condition for such profiling is that the Controller has the personal data of the given person in order to then send them, for example, a discount code.
5.4. The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them.
6. RIGHTS OF THE DATA SUBJECT
6.1. Right of access, rectification, restriction, erasure or portability. The data subject has the right to request from the Controller access to their personal data, rectification, erasure (“the right to be forgotten”). In addition, they have the right to restriction of processing and the right to object to processing, as well as the right to data portability. Detailed conditions for exercising the above rights are set out in Articles 15-21 of the GDPR Regulation.
6.2. The possibility to withdraw consent at any time. If personal data are processed by the Controller on the basis of consent given (pursuant to Article 6(1)(a) or Article 9(2)(a) of the GDPR Regulation), the data subject has the right to withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.
6.3. Right to lodge a complaint with a supervisory authority. The data subject whose data are processed by the Controller has the right to lodge a complaint. The complaint should be submitted to the supervisory authority in the manner and procedure specified in the provisions of the GDPR Regulation and Polish law, in particular the Personal Data Protection Act. The supervisory authority in Poland is the President of the Personal Data Protection Office.
6.4. Objection. The data subject has the right, at any time, to object – on grounds relating to their particular situation – to processing of personal data concerning them based on Article 6(1)(e) (public interest or official authority) or (f) (legitimate interests pursued by the controller), including profiling based on those provisions. In such a case, the Controller may no longer process those personal data, except where the Controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or grounds for the establishment, exercise or defence of legal claims.
6.5. Right to object to direct marketing. Where personal data are processed for direct marketing purposes, the data subject has the right to object at any time to processing of personal data concerning them for such marketing purposes. This includes, in particular, profiling, to the extent that the processing is related to such direct marketing.
6.6. In order to exercise the rights referred to in this section of the privacy policy, you may contact the Controller by sending an appropriate message in writing or by e-mail. Messages should be addressed to the Controller’s address indicated at the beginning of the privacy policy or by using the contact form available on the Online Store website.
7. COOKIES IN THE ONLINE STORE AND ANALYTICS
7.1. Cookies are small pieces of text information in the form of text files, sent by a server and saved on the side of the person visiting the Online Store website. They are stored on the hard drive of a computer or laptop, or on a smartphone memory card. This depends on the device used by the visitor of our Online Store. In addition, detailed information about cookies, as well as the history of their creation, can be found, among other places, here: https://pl.wikipedia.org/wiki/HTTP_cookie.
7.2. Cookies that may be sent by the Online Store website can be divided into different types according to the following criteria:
Based on their provider: first-party (created by the Controller’s Online Store website) and third-party (belonging to persons/entities other than the Controller)
| Based on their storage period on the device of the person visiting the Online Store website: session cookies (stored until logging out of the Online Store or closing the web browser) and persistent cookies (stored for a specified period defined by the parameters of each file or until manually deleted)
| Based on the purpose of their use: necessary (enabling proper functioning of the Online Store website), functional/preference cookies (enabling the Online Store website to be adjusted to the preferences of the person visiting the website), analytics and performance cookies (collecting information on how the Online Store website is used), marketing, advertising and social cookies (collecting information about the person visiting the Online Store website in order to display ads to them, personalise them, measure effectiveness and conduct other marketing activities, including on websites separate from the Online Store website, such as social networking sites or other websites belonging to the same advertising networks as the Online Store)
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7.3. The Controller may process data contained in cookies, in accordance with this privacy policy, when visitors use the Online Store website for the following specific purposes:
Purposes of using cookies in the Controller’s Online Store | identifying Service Recipients as logged in to the Online Store and showing that they are logged in (necessary cookies) |
remembering Products added to the cart in order to place an Order (necessary cookies) |
remembering data from completed Order Forms, surveys or login data to the Online Store (necessary and/or functional/preference cookies) |
adjusting the content of the Online Store website to the individual preferences of the Service Recipient (e.g., regarding colours, font size, page layout) and optimising the use of Online Store pages (functional/preference cookies) |
maintaining anonymous statistics showing how the Online Store website is used (analytics and performance cookies) |
displaying and rendering ads, limiting the number of ad impressions and ignoring ads that the Service Recipient does not want to see, measuring the effectiveness of ads, as well as personalising ads, i.e., studying the behavioural characteristics of persons visiting the Online Store through anonymous analysis of their actions (e.g., repeated visits to specific pages, keywords, etc.) in order to create their profile and provide them with ads tailored to their anticipated interests, also when they visit other websites within the advertising network of Google Ireland Ltd. and Facebook, i.e., Meta Platforms Ireland Ltd. (marketing, advertising and social cookies) |
7.4. Checking in the most popular web browsers which cookies (including the lifespan of cookies and their provider) are currently being sent by the Online Store website is possible as follows:
In the Chrome browser: (1) in the address bar, click the padlock icon on the left, (2) go to the “Cookies” tab. | In the Firefox browser: (1) in the address bar, click the shield icon on the left, (2) go to the “Allowed” or “Blocked” tab, (3) click the “Cross-site tracking cookies”, “Social media trackers” or “Content with trackers” field | In the Internet Explorer browser: (1) click the “Tools” menu, (2) go to the “Internet Options” tab, (3) go to the “General” tab, (4) go to the “Settings” tab, (5) click the “View files” field |
In the Opera browser: (1) in the address bar, click the padlock icon on the left, (2) go to the “Cookies” tab. | in the Safari browser: (1) click the “Preferences” menu, (2) go to the “Privacy” tab, (3) click “Manage Website Data” | Regardless of the browser, using tools available, for example, on the website: https://www.cookiemetrix.com/ or: https://www.cookie-checker.com/ |
7.5. By default, most web browsers available on the market accept the saving of cookies. Everyone has the possibility to specify the conditions for using cookies by means of the settings of their own web browser. This means that you can, for example, partially restrict (e.g., temporarily) or completely disable the ability to save cookies. In the latter case, as described in the privacy policy, this may affect certain functionalities of the Online Store. For example, it may become impossible to go through the Order path via the Order Form due to Products in the cart not being remembered during subsequent steps of placing an Order).
7.6. Web browser settings regarding cookies are important from the perspective of consent to the use of cookies by our Online Store. The Eurowolle privacy policy assumes that consent may also be expressed through web browser settings. Detailed information on changing cookie settings and on deleting cookies independently in the most popular web browsers is available in the browser help section and on the following browser websites (just click the relevant link):
in the Chrome browser
Firefox
Internet Explorer
Opera
Safari
Microsoft Edge
7.7. The Controller may use Google Analytics and Universal Analytics services provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) in the Online Store. These services help the Controller keep statistics and analyse traffic in the Online Store. In addition, the collected data are processed within the above services to generate statistics helpful in administering the Online Store and analysing traffic in the Online Store. These data are aggregated. When using the above services in the Online Store, the Controller collects data such as the sources and medium by which visitors are acquired. In addition, the manner of their behaviour on the Online Store website, information about the devices and browsers from which they visit the website, IP and domain, as well as geographic data and demographic data (age, gender) and interests.
7.8. It is possible for a person to easily block the sharing with Google Analytics of information about their activity on the Online Store website. To this end, for example, you can install the browser add-on provided by Google Ireland Ltd. available here: https://tools.google.com/dlpage/gaoptout?hl=pl.
7.9. In connection with the possibility that the Controller may use advertising and analytics services provided by Google Ireland Ltd. in the Online Store, the Controller indicates that full information on the principles of processing data of persons visiting the Online Store (including information saved in cookies) by Google Ireland Ltd. is included in the privacy policy of Google services available at: https://policies.google.com/technologies/partner-sites.
7.10. The Controller may use the Facebook Pixel service provided by Facebook Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) in the Online Store. This service helps the Controller measure the effectiveness of advertisements. In addition, it may learn what actions visitors to the Online Store take and display tailored advertisements to those persons. Detailed information on how the Facebook Pixel works can be found at the following internet address: https://www.facebook.com/business/help/742478679120153?helpref=page_content.
7.11. Managing the operation of the Facebook Pixel is possible via the ad settings in your account on Facebook.com: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen.
8. FINAL PROVISIONS
8.1. The Online Store may contain links to other websites. The Controller encourages you, after moving to other websites, to read the privacy policy established there. This privacy policy applies only to the Controller’s Online Store.