PRIVACY AND COOKIES POLICY
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 – GDPR) (UE L 119 s.1) – we undertake to respect your right to privacy in the Internet and make every effort to properly secure all personal data provided.
Personal Data Administrator
Administrator of your personal data („Administrator”) is 7Anna spółka z ograniczoną odpowiedzialnością sp. k. with its registered seat in Gdańsk (80-283), Poland, Potokowa Street, e-mail address: firstname.lastname@example.org, telephone number + 48 607 920 991.
Data Protection Officer
The Administrator has not appointed the Data Protection Officer. However, we undertake to take appropriate measures in order to protect against unauthorized access or disclosure of your data to third parties. Our databases are secured against access by third parties. In case of any doubts related to the processing of your data, do not hesitate to contact the Administrator using the above-mentioned contact details.
The purposes and legal basis of data processing, the legitimate interest of processing
Below we present to you all the standard purposes of the Administrator’s activities related to your data. The detailed purpose of processing your data is always communicated to you by the Administrator at the moment of obtaining your data. Your personal data may therefore be processed to:
conclusion and performance of contract(s), including the transaction services, problem solving and completion of your requests which are directed to us – because the data processing is necessary for the conclusion and implementation of contract(s) (Article 6 paragraph 1 letter b) GDPR);
providing services by electronic means and sending retail information – based on your consent (Article 6 paragraph 1 letter a) GDPR in relation to Article 10 paragraph 2 of the Act on the Providing Services by Electronic Means),
direct marketing of the goods or services, including contact, presenting the offer, conducting measures and analyzes, including profiling (i.e. using personal data to create your profile in terms of goods and services that you might be interested in), saving data in cookie files and collecting data from websites and mobile applications – based on your consent (Article 6 paragraph 1 letter a) GDPR in relation to Article 172 of Telecommunication Law),
fulfilment of legal obligations imposed on us under EU or Polish law (e.g. towards the President of the Office of Competition and Consumer Protection, tax offices) – because data processing is necessary to fulfil the legal requirements which we are subject to (Article 6 paragraph 1 letter c) GDPR),
providing payment services, ensuring the security services that we provide by electronic means, handling your requests, for instance through a contact form in case if they are not directly related to performance of the contract, debt collection, civil litigation, administration and mediation proceeding, data storage for archival purposes and ensuring accountability (in compliance with obligations required by the law) – because data processing is necessary to implement our legally legitimate interest, that is providing our services, handling your requests, the possibility of establishing, investigating or defending against claims, data archiving (Article 6 paragraph 1 point f) GDPR).
If you subscribe to our newsletter, then we will use the data necessary for this purpose or date provided to us separately by you for the purpose of regularly sending our newsletter by electronic means based on your consent.
You can unsubscribe from receiving the newsletter at any time by sending us a message with relevant information or by using the appropriate link in the newsletter. Once you demand to not receive the newsletter, we will delete your e-mail address, unless you expressly agree to continue using your data for other purposes or we entitled to continue using the data in the legally permitted cases.
Who and where the Administrator can transfer your data?
Your data will be accessed by, apart from employees, proxies and the members of the Administrator’s bodies, persons and entities ensuring operations, maintenance and service of IT systems and solutions used by the Administrator. In addition, depending on the nature of the case, your personal data may only be transferred by the Administrator to the following entities:
• entities cooperating with the Administrator and providing services necessary for the Administrator in the course of its operations, in particular to entities providing the Administrator with accounting, financial, legal or tax advice – these entities process data on the basis of a contract with the administrator and only in accordance with the Administrator’s orders.
• public authorities, including courts, at their reasonable request.
In order to perform the contract, we transfer your data to the courier company involved in the courier services, if it is necessary to deliver the ordered goods.
Google (Universal) Analitics Usage for the purposes of web analytics
The Website uses Google (Universal) Analytics, Google Inc.’s web analytics tool (www.google.com). The above – as part of the analysis and assessment of interests – serves to protect our legally legitimate interest, consisting in the optimal presentation of our offer. Google (Universal) Analytics uses methods that allow to analyze how you use the Website – for instance cookies. Automatically collected information about your use of the Website is usually transferred to a Google server in the United States and stored there. Due to the IP anonymization activated on the Website, your IP address is shortened before forwarding within the EU Member States or in other countries that are party to the Agreement on the European Economic Area. Only extraordinary situations, the full IP address is forwarded to a Google server in the United States and shortened there. The anonymized IP address provided by your browser as part of Google Analytics is in principle not combined with other Google data. Google LLC is headquartered in the USA and is EU-US-Privacy Shield certified. The current certificate is available at this link. Under the agreement between the US and the European Commission, the latter has found an adequate level of data protection for companies certified by Privacy Shield. You can prevent the registration of data collected by cookies on your use of our website (including your IP address) by Google, as well as the processing of this data by Google, if you download and install the browser plug-in located at this link. Alternatively – instead of that you can also click on this link to turn off the data collection through the Google Analytics Website. The cookie opt-out files will be saved on your device. If you delete cookies, you must click on the link above again.
Google AdWords Remarketing
With the help of Google Adwords, we promote the Service in search results and on third party websites. For this purpose, when visiting our website, the Google Remarketing cookie file is automatically left on the device, which with a pseudonymous identifier (ID) and based on the pages you visit allows you to display interest-based advertisements.
Data transfers outside the European Economic Area or to international organizations
In addition to the above-mentioned exceptions, your personal data will not be transferred outside of the European Economic Area or to international organizations.
How long will the Administrator store your data?
(Information about the storage period)
The storage period of your data by the Administrator will depend on the purpose of processing of your data.
In the event that your data is processed by the Administrator in order to perform the contract between you and the Administrator or to perform other obligations on your behalf by the Administrator (for instance to keep a customer account), your personal data will be kept by the Administrator for the period required to complete obligations of the Administrator for you, e.g. arising from the contract of sale and until the expiry of the period of limitation of all your claims against the Administrator and Administrator’s claims against you, related to such obligations, e.g. arising from the contract of sale, unless the storage of data will be longer necessary for the purposes of obligations tax – in this case, the removal will take place immediately after the expiration of the tax liabilities related to the obligation, for instance with the contract (e.g. for billing purposes related to the contract), your data will be stored for 5 years counting from the end of the year in which a given tax was due related to the contract has expired).
In the event that your data is processed by the Administrator due to the necessity of processing for purposes arising from the legitimate interests of the Administrator, your personal data will be kept by the Administrator for the period necessary to achieve the objectives arising from such interests, with the objective of direct marketing for the duration of the legitimate interest in marketing, unless you exercise your right and object to the processing of this data for marketing purposes. In this case, the Administrator may store your data for the period of limitation of your claims against the Administrator or the claims of the Administrator to you, resulting from the law, if the processing of these data will be necessary to establish or enforce claims, as well as to defend against such claims.
To implement the legitimate interests of the Administrator, including determining and pursuing claims or defending against claims, the Administrator may store your data for the period of limitation of your claims against the Administrator or Administrator’s claims against you resulting from legal provisions (for example, the general period of limitation of claims related to business operations is 3 years, and the general period of limitation for consumer claims against the Administrator is 10 years, the above periods of personal data storage may change as the general law changes).
To implement the legitimate interests of the Administrator, including the reply to your message, question, complaint or suggestion, the Administrator may store your data for the period necessary to answer or settle a matter with which you ask the Administrator, whereby the Administrator may extend this period for a period of limitation of your claims against the Administrator or the Administrator’s claims against you under the law, if the processing of such data is necessary to establish or enforce claims, as well as to defend against such claims.
In addition, in the event of a claim being brought against the Administrator or by the Administrator, for instance in connection with a sales contract between you and the Administrator, your data will be stored no longer than it will be necessary in connection with the appropriate proceedings regarding such claims.
If your data are processed by the Administrator due to the legal obligation imposed on the Administrator, the Administrator will keep this data for as long as the Administrator has a proper legal obligation. If your data is necessary to prove in writing economic events for accounting purposes, your data in this respect will be kept by the Administrator as long as there is a legal obligation for the Administrator to have a document of these events.
Information about your rights
The right to access your data
You have the right to request access to your personal data, including in particular information about whether the Administrator processes your personal data and the scope of data held by the Administrator, the purposes of data processing or the categories of recipients of your data, if possible, about the planned period of data storage, about your rights regarding personal data, information about the sources of data obtained by the Administrator, if they have not been collected from you. You also have the right to obtain a copy of the data, on condition that the first copy of the data is free and any subsequent copies may require a reasonable fee to cover the administrative costs of preparing such a copy of the data.
The right to rectify data
You have the right to request the rectification of incorrect data immediately or, taking into account the purposes of processing, to supplement incomplete data.
The right to remove your data (the right to be forgotten)
You have the right to request your data to be removed if one of the following circumstances applies:
• personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
• you have submitted effective objection to the processing data;
• personal data have been processed illegally;
• personal data must be removed in order to comply with the legal obligation;
• you revoked your consent to the processing of personal data which were processed on the basis of your consent and there is no other legal basis for their processing.
You will not be able to use the right to remove data, among others if such data is necessary to establish or enforce a claim or defend against claims.
The right to limit processing your data
You have the right to limit the process of your data on the following circumstances:
if you question the correctness of personal data – for the period allowing to check the correctness of data,
processing the data is illegal and you object the removal of data, requesting instead to limit their use;
personal data are no longer needed by the Administrator but you need to establish or enforce a claim or defend against claims;
in case of an objection brought by you – until it is determined whether the legitimate grounds on the part of the Administrator are overriding the grounds of your objection.
The right to transfer your data
You have the right to receive, in a structured, commonly used in readable format, your personal data that you provided to the Administrator and you have the right to forward this personal data to another administrator without any obstacles from the Administrator if:
• processing is carried out on the basis of your consent or on the basis of a contract with you and at the same time;
• processing takes place in an automated manner.
You also have the right to request that personal data are sent by the Administrator directly to another personal data administrator, if it is technically possible.
The right to object against processing your data
You have the right to object at any time – for reasons related to your particular situation – against the processing of your data, if the legal basis of the processing is the legitimate interest of the Administrator.
Due to the objection, the Administrator will cease to process your personal data, unless it demonstrates the existence of legally valid grounds for processing, interests principal to you, rights and freedoms or grounds for establishing, enforcing claims or defending against claims.
If personal data are processed for direct marketing purposes, you can object to such processing at any time, including profiling, without having to disclose the reasons related to your specific situation and the Administrator is obliged to cease such processing immediately.
The right to complain to the supervisory body
You have the right to lodge a complaint to the President of the Office for Personal Data Protection if you think that the processing of your personal data violates the law in this regard.
Information whether providing the personal data is a statutory or contractual requirement or a condition for the conclusion of a contract and no obligation to provide data
You provide all data voluntarily.
Depending on the situation in which the Administrator may obtain your data, providing certain data (specified by the Administrator as required data) may be a condition for entering into an agreement with the Administrator or a condition for the Administrator to start providing services such as opening and running by client accounts.
Providing the address data is necessary, for example, to order an offer. Providing a telephone number may be necessary to use additional services, for example to appoint a meeting. Providing your first name and surname (name), address and tax identification number may be a statutory requirement and necessary to prepare documentation for tax purposes.
In the case of sending messages or requests to the Administrator (e.g. sending an offer), providing contact details is not a statutory or contractual requirement or a condition to conclude a contract, however, providing the required data is necessary to enable the Administrator to respond.
Information on the consequences of not providing data
Depending on the situation in which the Administrator may obtain your data, failure to provide certain information may prevent the conclusion of the contract with the Administrator, use additional services, opening and maintaining your customer account, receiving correct tax documents from the Administrator, receiving from the Administrator offers or responses to message addressed to the Administrator, submission to the Administrator the complaints, interventions or changes an order.
Information on the use of data for automated decision-making, including profiling
Your personal data will not be used for automated decision making, including profiling.
What are cookies and how we use them?
Cookies are IT data, in particular text files, which are stored in your terminal device (e.g. computer). Cookies usually contain the name of the website from which they originate, their storage time on the end device and a unique number. Cookies are used to:
• adjusting the content of the Website to the user’s preferences and optimizing the use of websites; in particular, these files allow to recognize the Website user’s device and properly display the website, tailored to his individual needs;
• creating statistics that help to understand how Website’s users use it, which allows improving its structure and content;
• maintaining the Website user session.
The Website uses the following types of cookies:
• “necessary” cookies, enabling the use of services available on the Website, e.g. authentication cookies used for services that require authentication on the Website; cookies used to ensure security, e.g. used to detect fraud in the field of authentication on the Website;
• “performance” cookies, enabling the collection of information on the use of Website pages;
• “functional” cookies, allowing “remembering” the settings selected by the User and personalizing the User’s interface, e.g. in terms of the language or region of the User’s origin, size of the font, appearance of the website, etc .;
• “advertising” cookies, enabling users to provide advertising content more tailored to their interests.
In the auxiliary browser menu you will find explanations of changing cookie settings. Available at the following links:
Internet Explorer™: https://support.microsoft.com/pl-pl/help/17442/windows-internet-explorer-delete-manage-cookies