Privacy Policy
PRIVACY POLICY
OF THE ONLINE STORE safegel.com
TABLE OF CONTENTS:
- GENERAL PROVISIONS
- LEGAL BASES FOR DATA PROCESSING
- PURPOSE, LEGAL BASIS AND PERIOD OF DATA PROCESSING IN THE ONLINE STORE
- RECIPIENTS OF DATA IN THE ONLINE STORE
- PROFILING IN THE ONLINE STORE
- RIGHTS OF THE DATA SUBJECT
- COOKIES IN THE ONLINE STORE AND ANALYTICS
- FINAL PROVISIONS
- GENERAL PROVISIONS
- This Privacy Policy of the Online Store is informational in nature, which means that it does not create obligations for Service Recipients or Customers of the Online Store. The Privacy Policy primarily sets out the rules concerning the processing of personal data by the Controller in the Online Store, including the legal bases, purposes and periods of personal data processing and the rights of data subjects, as well as information concerning the use of Cookies and analytical tools in the Online Store.
- The controller of personal data collected through the Online Store is RENOVEY SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ, with its registered office in Ciechanowiec, entered in the Register of Entrepreneurs of the National Court Register under KRS number 0000838010, NIP 5252821058, REGON 38593425300000, correspondence address: ul. Dworska 34, 18-230 Ciechanowiec, Poland, email address: info@safegel.com, telephone number: +48221002085 – hereinafter referred to as the “Controller” and also acting as the Service Provider of the Online Store and the Seller.
- Personal data in the Online Store is processed by the Controller in accordance with applicable law, in particular 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, repealing Directive 95/46/EC (General Data Protection Regulation), hereinafter referred to as the “GDPR”. The official text of the GDPR is available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32016R0679
- Use of the Online Store, including making purchases, is voluntary. Likewise, providing personal data by a Service Recipient or Customer using the Online Store is voluntary, subject to two exceptions: (1) concluding agreements with the Controller – failure to provide personal data necessary to conclude and perform a Sales Agreement or an agreement for the provision of an Electronic Service, in cases and to the extent indicated on the Online Store website, in the Terms and Conditions of the Online Store and in this Privacy Policy, will result in the inability to conclude such an agreement. In such a case, providing personal data is a contractual requirement and, if the data subject wishes to conclude a given agreement with the Controller, they are required to provide the necessary data. The scope of data required to conclude an agreement is each time indicated in advance on the Online Store website and in the Terms and Conditions; (2) statutory obligations of the Controller – providing personal data may be a statutory requirement arising from generally applicable law imposing an obligation on the Controller to process personal data, for example for tax or accounting record-keeping. Failure to provide such data may prevent the Controller from fulfilling those legal obligations.
- The Controller takes particular care to protect the interests of persons whose personal data it processes and, in particular, is responsible for and ensures that the data collected by it is: (1) processed lawfully; (2) collected for specified and legitimate purposes and not further processed in a manner incompatible with those purposes; (3) accurate and adequate in relation to the purposes for which it is processed; (4) kept in a form permitting identification of data subjects for no longer than is necessary for the purposes of processing; and (5) processed in a manner ensuring appropriate security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.
- Taking into account the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity to the rights and freedoms of natural persons, the Controller implements appropriate technical and organizational measures to ensure that processing is carried out in accordance with the GDPR and to be able to demonstrate such compliance. These measures are reviewed and updated where necessary. The Controller applies technical measures preventing unauthorized persons from obtaining or modifying personal data transmitted electronically.
- All words, expressions and acronyms used in this Privacy Policy beginning with a capital letter, for example Seller, Online Store, Electronic Service, shall be understood in accordance with their definitions contained in the Terms and Conditions of the Online Store available on the Online Store website.
- LEGAL BASES FOR DATA PROCESSING
- The Controller is entitled to process personal data 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 an agreement 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 an agreement; (3) processing is necessary for compliance with a legal obligation to which the Controller is subject; or (4) processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
- The processing of personal data by the Controller always requires the existence of at least one of the legal bases indicated in Section 2.1 of this Privacy Policy. The specific legal bases for processing the personal data of Service Recipients and Customers of the Online Store by the Controller are indicated in the next section of the Privacy Policy in relation to each purpose of processing.
- PURPOSE, LEGAL BASIS AND PERIOD OF DATA PROCESSING IN THE ONLINE STORE
- In each case, the purpose, legal basis and period of processing, as well as the recipients of personal data processed by the Controller, depend on the actions undertaken by the relevant Service Recipient or Customer in the Online Store or by the Controller.
- The Controller may process personal data in connection with the Online Store for the following purposes, on the following legal bases and for the following periods:
| Purpose of processing | Legal basis for processing | Data retention period |
|---|---|---|
| Performance of a 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 such agreements | Article 6(1)(b) GDPR (performance of a contract) – processing is necessary for the performance of an agreement 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 an agreement | Data is stored for the period necessary to perform, terminate or otherwise expire the concluded Sales Agreement or agreement for the provision of an Electronic Service. |
| Direct marketing | Article 6(1)(f) GDPR (legitimate interests of the Controller) – processing is necessary for the purposes of the Controller’s legitimate interests consisting in protecting the interests and reputation of the Controller and its Online Store and pursuing sales of Products | Data is stored for the duration of the legitimate interest pursued by the Controller, but no longer than the limitation period for the Controller’s claims against the data subject arising from the Controller’s business activity. Limitation periods are determined by applicable law, in particular the Polish Civil Code. The Controller may not process personal data for direct marketing purposes where the data subject has effectively objected to such processing. |
| Marketing | Article 6(1)(a) GDPR (consent) – the data subject has given consent to the processing of their personal data for marketing purposes by the Controller | Data is stored until the data subject withdraws consent to further processing for this purpose. |
| Submission by the Customer of a review concerning a concluded Sales Agreement | Article 6(1)(a) GDPR – the data subject has given consent to the processing of their personal data for the purpose of submitting a review | Data is stored until the data subject withdraws consent to further processing for this purpose. |
| Keeping tax records | Article 6(1)(c) GDPR in connection with applicable Polish tax law – processing is necessary for compliance with a legal obligation to which the Controller is subject | Data is stored for the period required by applicable law obliging the Controller to retain tax records, generally until the expiry of the limitation period for the relevant tax liability unless tax law provides otherwise. |
| Establishment, exercise or defense of claims that may be raised by the Controller or against the Controller | Article 6(1)(f) GDPR (legitimate interests of the Controller) – processing is necessary for the purposes of the Controller’s legitimate interests consisting in establishing, exercising or defending legal claims | Data is stored for the duration of the legitimate interest pursued by the Controller, but no longer than the limitation period for claims that may be brought against the Controller. |
| Use of the Online Store website and ensuring its proper operation | Article 6(1)(f) GDPR (legitimate interests of the Controller) – processing is necessary for the purposes of the Controller’s legitimate interests consisting in operating and maintaining the Online Store website | Data is stored for the duration of the legitimate interest pursued by the Controller, but no longer than the applicable limitation period for claims arising from the Controller’s business activity. |
| Keeping statistics and analyzing traffic in the Online Store | Article 6(1)(f) GDPR (legitimate interests of the Controller) – processing is necessary for the purposes of the Controller’s legitimate interests consisting in keeping statistics and analyzing traffic in the Online Store in order to improve the functioning of the Online Store and increase sales of Products | Data is stored for the duration of the legitimate interest pursued by the Controller, but no longer than the applicable limitation period for claims arising from the Controller’s business activity. |
- RECIPIENTS OF DATA IN THE ONLINE STORE
- For the proper functioning of the Online Store, including performance of concluded Sales Agreements, it is necessary for the Controller to use services provided by external entities, such as software providers, couriers or payment service providers. The Controller uses only processors that provide sufficient guarantees to implement appropriate technical and organizational measures so that processing meets GDPR requirements and protects the rights of data subjects.
- Personal data may be transferred by the Controller to a third country. In such a case, the Controller ensures that the transfer takes place to a country ensuring an adequate level of protection in accordance with the GDPR or, in the case of other countries, on the basis of appropriate safeguards, including standard contractual clauses where applicable. The Controller ensures that the data subject may obtain information concerning applicable safeguards. The Controller transfers collected personal data only where, and to the extent that, it is necessary to achieve a specific processing purpose consistent with this Privacy Policy.
- Data is not transferred by the Controller in every case and not to all recipients or categories of recipients indicated in this Privacy Policy. The Controller transfers data only where necessary to achieve a specific purpose of personal data processing and only to the extent necessary to achieve that purpose. 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 / entities handling warehousing and/or the shipping process – where a Customer uses postal or courier delivery in the Online Store, the Controller makes the Customer’s collected personal data available to the selected carrier, freight forwarder or intermediary carrying out shipments on behalf of the Controller, or, if shipment is made from an external warehouse, to the entity handling warehousing and/or the shipping process, to the extent necessary to deliver the Product to the Customer.
- entities handling electronic or payment card payments – where a Customer uses electronic payment or payment card payment in the Online Store, the Controller makes the Customer’s collected personal data available to the selected payment service provider acting on behalf of the Controller to the extent necessary to process the Customer’s payment.
- providers of review survey systems – where a Customer has agreed to submit a review concerning a concluded Sales Agreement, the Controller makes the Customer’s collected personal data available to the selected provider of a review survey system for Sales Agreements in the Online Store, acting on behalf of the Controller, to the extent necessary to enable the Customer to submit a review through such system.
- service providers supplying the Controller with technical, IT and organizational solutions enabling the Controller to conduct its business, including the Online Store and the Electronic Services provided through it – in particular providers of software used to operate the Online Store, email and hosting providers and providers of business management and technical support software. The Controller makes collected personal data available to the selected provider acting on its behalf only where and to the extent necessary to achieve a specific processing purpose consistent with this Privacy Policy.
- providers of accounting, legal and advisory services supporting the Controller – in particular accounting firms, law firms and debt collection agencies. The Controller makes collected personal data available to the selected provider acting on its behalf only where and to the extent necessary to achieve a specific processing purpose consistent with this Privacy Policy.
- PROFILING IN THE ONLINE STORE
- The GDPR requires the Controller to provide information about automated decision-making, including profiling referred to in Article 22(1) and (4) GDPR, and, at least in such cases, meaningful information about the logic involved as well as the significance and envisaged consequences of such processing for the data subject. In view of this, the Controller provides information concerning possible profiling in this section of the Privacy Policy.
- The Controller may use profiling in the Online Store for direct marketing purposes, but decisions taken by the Controller on the basis of such profiling do not concern the conclusion or refusal to conclude a Sales Agreement or the possibility of using Electronic Services in the Online Store. Profiling may result, for example, in granting a discount to a given person, sending a discount code, reminding them about an unfinished purchase, sending a proposal for a Product that may match their interests or preferences, or offering more favorable conditions than the standard offer of the Online Store. Despite profiling, the person remains free to decide whether to use the discount or other offered conditions and make a purchase in the Online Store.
- Profiling in the Online Store consists in the automated analysis or prediction of a person’s behavior on the Online Store website, for example by adding a specific Product to the shopping cart, viewing a particular Product page or analyzing previous purchase history in the Online Store. Such profiling requires the Controller to possess personal data relating to the person so that it may subsequently, for example, send a discount code.
- 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.
- RIGHTS OF THE DATA SUBJECT
- Right of access, rectification, restriction, erasure or data portability – the data subject has the right to request from the Controller access to their personal data, rectification, erasure (“right to be forgotten”) or restriction of processing, as well as the right to object to processing and the right to data portability. Detailed conditions for exercising these rights are set out in Articles 15–21 GDPR.
- Right to withdraw consent at any time – where personal data is processed by the Controller on the basis of consent, including pursuant to Article 6(1)(a) or Article 9(2)(a) GDPR, the data subject has the right to withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
- Right to lodge a complaint with a supervisory authority – a person whose data is processed by the Controller has the right to lodge a complaint with a supervisory authority in the manner and according to the procedure specified in the GDPR and Polish law, in particular the Polish Act on Personal Data Protection. The supervisory authority in Poland is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych).
- Right to object – the data subject has the right to object at any time, on grounds relating to their particular situation, to processing of personal data concerning them which is based on Article 6(1)(e) or (f) GDPR, including profiling based on those provisions. In such a case, the Controller may no longer process the personal data unless it 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 defense of legal claims.
- Right to object to direct marketing – where personal data is 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, including profiling to the extent that it is related to such direct marketing.
- To exercise the rights referred to in this section of the Privacy Policy, the data subject may contact the Controller by sending an appropriate written message or email to the Controller’s address indicated at the beginning of this Privacy Policy or by using the contact form available on the Online Store website.
- COOKIES IN THE ONLINE STORE AND ANALYTICS
- Cookies are small pieces of textual information in the form of text files sent by a server and stored on the device of a person visiting the Online Store website, for example on the hard drive of a computer or laptop or in the memory of a smartphone, depending on the device used to visit the Online Store.
- Cookies that may be sent by the Online Store website may be divided into different types according to the following criteria:
| By provider | By storage period on the visitor’s device | By purpose |
| First-party cookies, created by the Controller’s Online Store website, and third-party cookies belonging to persons/entities other than the Controller | Session cookies, stored until logging out of the Online Store or closing the browser, and persistent cookies, stored for a specified period defined by the parameters of each cookie or until manually deleted | Necessary cookies, enabling proper operation of the Online Store website; functional/preference cookies, enabling adaptation of the Online Store website to visitor preferences; analytical and performance cookies, collecting information on use of the Online Store website; marketing, advertising and social media cookies, collecting information about visitors for the purpose of displaying advertisements, personalizing them, measuring their effectiveness and carrying out other marketing activities, including on websites separate from the Online Store, such as social media or other websites belonging to the same advertising networks |
- The Controller may process data contained in Cookies when visitors use the Online Store website for the following specific purposes:
- identifying Service Recipients as logged in to the Online Store and showing that they are logged in – necessary Cookies;
- remembering Products added to the shopping cart for the purpose of placing an Order – necessary Cookies;
- remembering data from Order Forms, surveys or login details – necessary and/or functional/preference Cookies;
- adapting the content of the Online Store website to the Service Recipient’s individual preferences, for example colors, font size or page layout, and optimizing use of the Online Store – functional/preference Cookies;
- keeping anonymous statistics showing how the Online Store website is used – analytical and performance Cookies;
- displaying and rendering advertisements, limiting the number of times advertisements are displayed, disregarding advertisements that the Service Recipient does not wish to see, measuring advertising effectiveness and personalizing advertisements, including analysis of visitor behavior in order to create profiles and provide advertising tailored to predicted interests, including when visitors use other websites in advertising networks such as those operated by Google Ireland Ltd. and Meta Platforms Ireland Ltd. – marketing, advertising and social media Cookies.
- Information about Cookies currently being sent by the Online Store website, including their duration and provider, can generally be checked through the privacy, site information, developer or cookie settings available in the user’s web browser.
- Most web browsers available on the market accept Cookies by default. Every user may determine the conditions for the use of Cookies through their browser settings. This means that the possibility of storing Cookies may, for example, be partially restricted or completely disabled. However, disabling Cookies may affect some functionality of the Online Store, for example it may prevent completion of the ordering process if Products are not remembered in the shopping cart during subsequent steps.
- Browser settings concerning Cookies are relevant from the point of view of consent to the use of Cookies by the Online Store. Depending on applicable law and the type of Cookie, consent may be managed through the browser settings or through the consent management mechanism made available on the Online Store website. Detailed information on changing Cookie settings and deleting Cookies is available in the help section of the relevant browser.
- The Controller may use analytics services provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland), including Google Analytics. These services help the Controller keep statistics and analyze traffic in the Online Store. Data collected through these services may include traffic source and acquisition medium, behavior on the Online Store website, information about devices and browsers used to access the website, IP address and domain information, geographic data and, where applicable, demographic and interest-related information.
- A person may limit the sharing of information with Google Analytics concerning their activity on the Online Store website, for example by using privacy controls made available by Google or by installing a browser add-on made available by Google Ireland Ltd. where such functionality is available.
- In connection with the possibility of the Controller using advertising and analytical services provided by Google Ireland Ltd., the Controller indicates that further information on the processing of data of persons visiting websites and using Google services, including information stored in Cookies, is available in Google’s privacy documentation at: https://policies.google.com/technologies/partner-sites.
- FINAL PROVISIONS
- The Online Store may contain links to other websites. The Controller recommends reviewing the privacy policy applicable to any external website after following such a link. This Privacy Policy applies only to the Controller’s Online Store.