TABLE OF CONTENTS:

1. GENERAL PROVISIONS

2. BASES FOR DATA PROCESSING

3. PURPOSE, BASIS AND PERIOD OF DATA PROCESSING IN THE ONLINE STORE

4. DATA RECIPIENTS IN THE ONLINE STORE

5. PROFILING IN THE ONLINE STORE

6. RIGHTS OF THE DATA SUBJECT

7. COOKIES IN THE ONLINE STORE AND ANALYTICS

8. FINAL PROVISIONS

 

1.      GENERAL PROVISIONS

1.1.              This Privacy Policy of the Online Store is for informational purposes only, which means that it does not create any obligations for Service Users or Customers of the Online Store. The Privacy Policy primarily contains rules regarding the processing of personal data by the Administrator in the Online Store, including the bases, purposes and period of personal data processing and the rights of data subjects, as well as information on the use of Cookies and analytical tools in the Online Store.

1.2.              The Administrator of personal data collected via the Online Store is FRIZLE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ, entered in the Central Register and Information on Economic Activity of the Republic of Poland kept by the minister responsible for economy, having: business address: ul. Hoża 86/410, 00-682 Warsaw and correspondence address: the same, NIP 7011225172, REGON 529779614, email address: info@frizle.pl, phone number: 787907879 – hereinafter referred to as the "Administrator" and simultaneously being the Service Provider of the Online Store and the Seller.

1.3.              Personal data in the Online Store is processed by the Administrator in accordance with applicable law, in particular in accordance with 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 "GDPR" or "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. Similarly, the provision of personal data by a Service User or Customer using the Online Store is voluntary, with two exceptions: (1) concluding contracts with the Administrator – failure to provide personal data necessary for the conclusion and performance of a Sales Contract or an Electronic Service contract with the Administrator, in cases and to the extent indicated on the Online Store website and in the Online Store Regulations and this privacy policy, will result in the inability to conclude such a contract. In such a case, providing personal data is a contractual requirement, and if the data subject wishes to conclude a given contract with the Administrator, they are obliged to provide the required data. The scope of data required for concluding a contract is always indicated beforehand on the Online Store website and in the Online Store Regulations; (2) Administrator's statutory obligations – the provision of personal data is a statutory requirement resulting from generally applicable legal provisions that impose an obligation on the Administrator to process personal data (e.g., processing data for tax or accounting purposes), and failure to provide them will prevent the Administrator from fulfilling these obligations.

1.5.              The Administrator takes special care to protect the interests of persons whose personal data are processed by him, and in particular is responsible for and ensures that the data collected by him are: (1) processed lawfully; (2) collected for specified, legitimate 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 that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; and (5) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.

1.6.              Taking into account the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for the rights and freedoms of natural persons, the Administrator implements appropriate technical and organisational measures to ensure and to be able to demonstrate that processing is performed in accordance with this Regulation. These measures are reviewed and updated where necessary. The Administrator applies technical measures to prevent unauthorised persons from obtaining and modifying personal data transmitted electronically.

1.7.              All words, phrases, and acronyms appearing in this privacy policy and starting with a capital letter (e.g., Seller, Online Store, Electronic Service) should be understood in accordance with their definition contained in the Online Store Regulations available on the Online Store pages.

2.      BASES FOR DATA PROCESSING

2.1.              The Administrator 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 his or her personal data for one or more specific purposes; (2) processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract; (3) processing is necessary for compliance with a legal obligation to which the Administrator is subject; or (4) processing is necessary for the purposes of the legitimate interests pursued by the Administrator 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.

2.2.              The processing of personal data by the Administrator always requires at least one of the bases indicated in point 2.1 of the privacy policy. Specific bases for processing personal data of Service Users and Customers of the Online Store by the Administrator are indicated in the next point of the privacy policy – in relation to the specific purpose of personal data processing by the Administrator.

3.      PURPOSE, BASIS AND PERIOD OF DATA PROCESSING IN THE ONLINE STORE

3.1.              The purpose, basis, period, and recipients of personal data processed by the Administrator always result from the actions taken by a given Service User or Customer in the Online Store or by the Administrator. For example, if a Customer decides to make purchases in the Online Store and chooses personal pickup of the purchased Product instead of courier delivery, their personal data will be processed for the purpose of fulfilling the concluded Sales Contract, but will no longer be shared with the carrier delivering shipments on behalf of the Administrator.  

3.2.              The Administrator may process personal data within the Online Store for the following purposes, on the bases and for the periods indicated in the table below:

 

Purpose of data processing	Legal basis for data processing	Data storage period
Performance of a Sales Contract or an Electronic Service contract or taking action at the request of the data subject prior to entering into the aforementioned contracts	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 party or in order to take steps at the request of the data subject prior to entering into a contract	Data is stored for the period necessary for the performance, termination, or other expiry of the concluded Sales Contract or Electronic Service contract.
Direct marketing	Article 6(1)(f) of the GDPR Regulation (legitimate interest of the administrator) – processing is necessary for the purposes of the legitimate interests pursued by the Administrator – consisting of caring for the interests and good image of the Administrator, its Online Store, and striving to sell Products	Data is stored for the period of the existence of the legitimate interest pursued by the Administrator, but no longer than for the period of limitation of the Administrator's claims against the data subject arising from the Administrator's business activity. The limitation period is determined by legal provisions, in particular the Civil Code (the basic limitation period for claims related to business activity is three years, and for a Sales Contract, two years). The Administrator cannot process data for direct marketing purposes if the data subject effectively objects to this.
Marketing	Article 6(1)(a) of the GDPR Regulation (consent) – the data subject has given consent to the processing of their personal data for marketing purposes by the Administrator	Data is stored until the data subject withdraws consent for further processing of their data for this purpose.
Maintaining accounting records	Article 6(1)(c) of the GDPR Regulation in conjunction with Article 74(2) of the Accounting Act of January 30, 2018 (Journal of Laws of 2018, item 395) – processing is necessary for compliance with a legal obligation to which the Administrator is subject	Data is stored for the period required by law obliging the Administrator to keep accounting records (5 years, counting from the beginning of the year following the financial year to which the data relates).
Establishing, pursuing or defending claims that the Administrator may raise or that may be raised against the Administrator	Article 6(1)(f) of the GDPR Regulation (legitimate interest of the administrator) – processing is necessary for the purposes of the legitimate interests pursued by the Administrator – consisting of establishing, pursuing or defending claims that the Administrator may raise or that may be raised against the Administrator	Data is stored for the period of the existence of the legitimate interest pursued by the Administrator, but no longer than for the period of limitation of claims that may be raised against the Administrator (the basic limitation period for claims against the Administrator is six years).
Using the Online Store website and ensuring its proper functioning	Article 6(1)(f) of the GDPR Regulation (legitimate interest of the administrator) – processing is necessary for the purposes of the legitimate interests pursued by the Administrator – consisting of operating and maintaining the Online Store website	Data is stored for the period of the existence of the legitimate interest pursued by the Administrator, but no longer than for the period of limitation of the Administrator's claims against the data subject arising from the Administrator's business activity. The limitation period is determined by legal provisions, in particular the Civil Code (the basic limitation period for claims related to business activity is three years, and for a Sales Contract, two years).
Conducting statistics and analyzing traffic in the Online Store	Article 6(1)(f) of the GDPR Regulation (legitimate interest of the administrator) – processing is necessary for the purposes of the legitimate interests pursued by the Administrator – consisting of conducting statistics and analyzing traffic in the Online Store to improve the functioning of the Online Store and increase sales of Products	Data is stored for the period of the existence of the legitimate interest pursued by the Administrator, but no longer than for the period of limitation of the Administrator's claims against the data subject arising from the Administrator's business activity. The limitation period is determined by legal provisions, in particular the Civil Code (the basic limitation period for claims related to business activity is three years, and for a Sales Contract, two years).

 

4.      DATA RECIPIENTS IN THE ONLINE STORE

4.1.              For the proper functioning of the Online Store, including for the execution of concluded Sales Contracts, it is necessary for the Administrator to use the services of external entities (such as, for example, a software provider, courier, or payment processing entity). The Administrator uses only the services of such processors who provide sufficient guarantees of implementing appropriate technical and organizational measures to ensure that processing meets the requirements of the GDPR Regulation and protects the rights of data subjects.

4.2.              The transfer of data by the Administrator does not occur in every case and not to all recipients or categories of recipients indicated in the privacy policy – the Administrator transfers data only when it is necessary for the realization of a given purpose of personal data processing and only to the extent necessary for its realization. For example, if a Customer uses personal pickup, their data will not be transferred to the carrier cooperating with the Administrator.

4.3.              Personal data of Service Users and Customers of the Online Store may be transferred to the following recipients or categories of recipients:

• carriers / freight forwarders / courier brokers / warehouse and/or shipping process handling entities – in the case of a Customer who uses postal or courier delivery for a Product in the Online Store, the Administrator provides the collected personal data of the Customer to the chosen carrier, freight forwarder, or intermediary performing shipments on behalf of the Administrator, and if the shipment is from an external warehouse – to the entity handling the warehouse and/or shipping process – to the extent necessary to deliver the Product to the Customer.

• entities handling electronic payments or credit card payments – in the case of a Customer who uses electronic payments or credit card payments in the Online Store, the Administrator provides the collected personal data of the Customer to the selected entity handling the above payments in the Online Store on behalf of the Administrator to the extent necessary to handle the payment made by the Customer.

• service providers supplying the Administrator with technical, IT and organisational solutions, enabling the Administrator to conduct business, including the Online Store and Electronic Services provided through it (in particular providers of computer software for running the Online Store, email and hosting providers, and software providers for company management and technical support for the Administrator) – the Administrator provides the collected personal data of the Customer to the selected provider acting on its behalf only if and to the extent necessary to achieve the given purpose of data processing in accordance with this privacy policy.

• providers of accounting, legal and advisory services providing the Administrator with accounting, legal or advisory support (in particular, an accounting firm, law firm or debt collection company) – the Administrator provides the collected personal data of the Customer to the selected provider acting on its behalf only if and to the extent necessary to achieve the given purpose of data processing in accordance with this privacy policy.

• Facebook Ireland Ltd. – The Administrator uses social plugins of the Facebook service on the Online Store website (e.g., Like button, Share, or logging in using Facebook login credentials) and therefore collects and shares personal data of the Service User using the Online Store website with Facebook Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland) to the extent and in accordance with the privacy principles available here: https://www.facebook.com/about/privacy/ (this data includes information about activities on the Online Store website – including information about the device, visited websites, purchases, displayed ads, and how services are used – regardless of whether the Service User 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 Administrator an obligation to inform about automated decision-making, including profiling, as referred to in Article 22(1) and (4) of the GDPR Regulation, and – at least in those cases – meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject. In view of this, the Administrator provides information regarding possible profiling in this point of the privacy policy.

5.2. The Administrator may use profiling in the Online Store for direct marketing purposes, but decisions made by the Administrator based on it do not concern the conclusion or refusal to conclude a Sales Agreement or the ability to use Electronic Services in the Online Store. The effect of using profiling in the Online Store may be, for example, granting a specific person a discount, sending them a discount code, reminding them about unfinished purchases, sending a proposal for a Product that may match the interests or preferences of that person, or offering better conditions compared to the standard offer of the Online Store. Despite profiling, the person concerned freely decides whether they want to use the discount or better conditions received in this way and make a purchase in the Online Store.

5.3. Profiling in the Online Store involves the automatic analysis or prediction of a person's behaviour on the Online Store's website, e.g., by adding a specific Product to the cart, browsing the page of a specific Product in the Online Store, or by analysing the history of purchases made in the Online Store. The condition for such profiling is that the Administrator has the personal data of the person concerned in order to be able to 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 him or her or similarly significantly affects him or her.

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 Administrator access to their personal data, their rectification, erasure ("right to be forgotten") or restriction of processing, and has the right to object to processing, as well as the right to data portability. The detailed conditions for exercising the above rights are set out in Articles 15-21 of the GDPR Regulation.

6.2. Right to withdraw consent at any time – if personal data is processed by the Administrator 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 without affecting 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 – a person whose data is processed by the Administrator has the right to lodge a complaint with a 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. Right to object – the data subject has the right to object at any time – on grounds relating to his or her particular situation – to processing of personal data concerning him or her which is based on Article 6(1)(e) (public interest or official authority) or (f) (legitimate interests of the controller), including profiling based on those provisions. In such a case, the Administrator shall no longer process the personal data unless he demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

6.5. Right to object to direct marketing – if personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it 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 Administrator by sending a written message or an email to the Administrator's address provided at the beginning of the privacy policy or by using the contact form available on the Online Store's website.

7. COOKIES IN THE ONLINE STORE AND ANALYTICS

7.1. Cookies are small text files, sent by the server and stored on the side of the person visiting the Online Store's website (e.g., on the hard drive of a computer, laptop, or on the memory card of a smartphone – depending on the device used by the visitor to our Online Store). Detailed information about Cookies, as well as their history, can be found, among others, here: http://pl.wikipedia.org/wiki/Ciasteczko.

7.2. The Administrator may process data contained in Cookies when visitors use the Online Store's website for the following purposes:

• identifying Service Users as logged in to the Online Store and showing that they are logged in;

• remembering Products added to the cart to place an Order;

• remembering data from completed Order Forms, surveys, or login data to the Online Store;

• adapting the content of the Online Store's website to the individual preferences of the Service User (e.g., regarding colours, font size, page layout) and optimizing the use of the Online Store's pages;

• conducting anonymous statistics showing how the Online Store's website is used;

• remarketing, i.e., examining the behaviour characteristics of Online Store visitors through anonymous analysis of their actions (e.g., repeated visits to specific pages, keywords, etc.) to create their profile and deliver advertisements tailored to their predicted interests, even when they visit other websites in the advertising network of Google Ireland Ltd. and Facebook Ireland Ltd.

7.3. By default, most web browsers available on the market accept the saving of Cookies. Everyone has the ability to define the conditions for the use of Cookies through their own web browser settings. This means that you can, for example, partially limit (e.g., temporarily) or completely disable the ability to save Cookies – in the latter case, however, this may affect some functionalities of the Online Store (for example, it may be impossible to complete the Order path through the Order Form due to Products not being remembered in the cart during subsequent steps of placing the Order).

7.4. The web browser settings regarding Cookies are important from the point of view of consent to the use of Cookies by our Online Store – in accordance with the regulations, such consent can also be expressed through the web browser settings. If such consent is not given, the web browser settings regarding Cookies should be changed accordingly.

7.5. Detailed information on how to change cookie settings and how to delete them independently in the most popular web browsers is available in the web browser's help section and on the following pages (just click on the link):

in Chrome browser

in Firefox browser

in Internet Explorer browser

in Opera browser

in Safari browser

in Microsoft Edge browser

7.6. The Administrator may use Google Analytics, Universal Analytics services in the Online Store provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). These services help the Administrator to keep statistics and analyze traffic in the Online Store. The collected data is processed within the framework of the above services to generate statistics useful for administering the Online Store and analyzing traffic in the Online Store. This data is aggregated. By using the above services in the Online Store, the Administrator collects data such as the sources and medium of acquiring visitors to the Online Store and their behaviour on the Online Store's website, information about the devices and browsers from which they visit the website, IP and domain, geographical data, and demographic data (age, gender) and interests.

7.7. It is possible for a person to easily block the sharing of information about their activity on the Online Store's website with Google Analytics – for this purpose, one can, for example, install a browser add-on provided by Google Ireland Ltd. available here: https://tools.google.com/dlpage/gaoptout?hl=pl.

7.8. The Administrator may use the Facebook Pixel service in the Online Store provided by Facebook Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland). This service helps the Administrator measure the effectiveness of advertisements and learn what actions Online Store visitors take, as well as display tailored advertisements to these individuals. Detailed information on the operation of the Facebook Pixel can be found at the following internet address: https://www.facebook.com/business/help/742478679120153?helpref=page_content.

7.9. Managing the operation of the Facebook Pixel is possible through the advertising settings in your Facebook.com account: 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 Administrator encourages you to review the privacy policy established there after going to other websites. This privacy policy applies only to the Administrator's Online Store.