Privacy policy for website regulations (information services only)

I

[Content of the administrator's privacy policy]

1. The privacy policy of the controller is information regarding the processing of personal data and other information concerning users of the website www.luxtrade.pl (hereinafter referred to as the "Site"). At the same time, in this privacy policy, the controller has included all the information that data subjects should receive in accordance with the RODO).
2. The privacy policy contains information about the processing of data obtained by the Site. Detailed information on the use of cookies or other similar technologies can also be found in the Cookie Policy available here.
3. In matters not regulated by the Privacy Policy, the provisions of the Civil Code and relevant laws of Poland, as well as the laws of the European Union, in particular RODO (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) shall apply.

II

[Data Administrator]

1. The administrator of the personal data of users of the Site is: Luxtrade II sp. z o. o. (formerly: Luxtrade sp. z o. o. sp. k.) with its registered office at 13 Rybnicka Street,43-200 Pszczyna, KRS: 0001082010, NIP: 6381825171, REGON: 367781154, e-mail:kontakt@luxtrade.pl (administrator's name, address of its registered office, designation according to the register of entrepreneurs) The administrator can be contacted by:
   1. Luxtrade II sp. z o. o. (formerly: Luxtrade sp. z o. o. sp. k.)at the mailing address: 43-200 Pszczyna ul.Rybnicka 13
   2. at e-mail address: kontakt@luxtrade.pl.
   (2) The Administrator undertakes to maintain secrecy related to personal data and their proper protection.

III

[Purposes, legal basis and time of data processing].

1. Operation of the Site
   1. For the purpose of implementation, the service provider processes:
      1. information about the user's device in order to ensure the correct operation of the services: the computer's IP address, information contained in cookies or other similar technologies, session data, browser data, device data, data about activity on the Site, including on individual subpages;
      2. geolocation information, if the user has consented to the service provider's access to geolocation. Geolocation information is used to provide more customized offers of products and services.
   2. Placing an order through the Site
      1. In order to perform the contract, the service provider processes personal data of users placing an order through the Site, i.e.: e-mail address, first name, last name, postal code of the locality, town, street with house and apartment number, telephone number. In the course of processing the order placed, the service provider may process a number of other information, including information about the user's use of the services, cookies or other similar technologies, device information.
      2. This data is processed in accordance with Article 6(1)(b) of the RODO in order to perform the services, i.e. the contract for the provision of electronic services in accordance with the terms and conditions available here, and is processed for the time necessary for as long as it is necessary to perform the contract, and thereafter for the period corresponding to the period of limitation of claims. Unless a special provision provides otherwise, the statute of limitations is six years, and for claims for periodic benefits and claims related to the conduct of business - three years.
   3. The data is processed in accordance with Article 6(1)(b) of the RODO, in order to perform the service of the Site, i.e. the contract for the provision of electronic services in accordance with the terms and conditions available here, and in accordance with Article 6(1)(a) of the RODO in connection with the consent to the use of certain cookies or other similar technologies, expressed by the relevant settings of the Internet browser in accordance with the Telecommunications Law, or in connection with the consent to geolocation. Data is processed until the user's use of the Site is terminated.
   4. Complaints:
   5. In order to process complaints, the service provider processes the personal data of users submitting complaints, in particular the e-mail address, name, the content of the complaint, the circumstances of the event giving rise to the complaint, information obtained in the course of processing the complaint, including the explanation of the event giving rise to the complaint. In the course of complaint processing, the service provider may process a range of other information, including the user's name, information about the user's use of the services, cookies or other similar technologies, device information.
2. 1. This data is processed in accordance with Article 6(1)(b) of the RODO for the purpose of performing the services, i.e. the contract for the provision of electronic services in accordance with the terms and conditions available here, and is processed for the time necessary to process the complaint and for no longer than 3 months after the end of the complaint procedure for archiving purposes in case of the need to defend against possible claims against the service provider as stated below.
3. Investigations, investigation of claims
   1. If an investigation is undertaken regarding a possible violation of the Terms of Service or the law, rules of social coexistence or good morals, proceedings to assert claims by the administrator or by other users or entities, defense against claims by users or other entities, the administrator may process the personal data of certain users until the completion of the pending proceedings and until the expiration of the statute of limitations of the administrator's claims against the user, which is usually 3 years in accordance with the Civil Code, but may be longer in special cases provided by law.
   2. If the personal data will be processed for the purpose of pursuing the claims of other users, the data may be made available for this purpose to another user or entity or to a public authority authorized by law, such as courts, police, prosecutor's office.
   3. The data will then be processed, including shared, in accordance with Article 6(1)(c) of the RODO, i.e. for the purpose of fulfilling an obligation under the law regarding the obligation to handle complaints, in accordance with the Act on Provision of Electronic Services, or in accordance with Article 6(1)(f) of the RODO, i.e. for the administrator's legitimate interest in pursuing its claims against the user. The administrator's legitimate interest will then be an objective that overrides the rights and freedoms of the service recipient.
4. Service usage statistics
   1. In order to improve the quality of its services, the administrator processes statistical information about the use of the Site, including information about the session, IP number, the amount of time spent on individual pages and subpages, use of individual functionalities of the services, device and browser information. The Administrator uses cookies or other similar technologies and statistical tools provided by. Detailed information about the use of cookies or other similar technologies can be found here.
   2. This data is processed in accordance with Article 6(1)(f) of the RODO for the legitimate interest of the administrator in facilitating the use of the Site, improving the quality and functionality of the services provided, and the processing of this data does not violate the rights and freedoms of users. This is because user information is not used for any additional purposes, and due to the nature of the Website service, adjusting the way the Website content is displayed, facilitating the use of the Website and improving the quality of service provision on the Website is not only a market standard, but also an expectation of users from Website providers.
   3. In addition, the user can revoke the consent given at any time by changing the settings of the web browser regarding the permissibility of using cookies or other similar technologies.
   4. The data is processed as part of the administrator's ongoing activities, but for no longer than 60 days after receiving the information. After this time, the administrator may continue to process general statistical data, which will be devoid of any information about individual users.
   5. However, the period of availability of statistical data in the tools provided by may be longer than 60 days, but this is beyond the administrator's discretion. The administrator will no longer use them, but will have potential access to them until they are deleted by the provider of the aforementioned tool.
5. Marketing and PR activities of the administrator

   The administrator may post marketing information about its products or services on the Site. Displaying this content is done by the administrator in accordance with Article 6(1)(f) of the RODO, in accordance with the administrator's legitimate interest in publishing content related to the services provided and promotional content of campaigns in which the administrator is involved. At the same time, this action does not violate the rights and freedoms of users, users expect to receive content of similar content, and sometimes even expect it or it is their direct purpose of visiting the Site.

6. Marketing activities of other products or services
   1. The Administrator may also post marketing information about the products or services of its contractors with whom it has entered into a marketing cooperation agreement.
   2. Displaying this content is done by the administrator in accordance with Article 6(1)(f) of the RODO, in accordance with the administrator's legitimate interest in marketing the products or services of its contractors. At the same time, this activity does not infringe on the rights and freedoms of users, particularly due to the sporadic nature of these activities, and users expect to receive content of similar content due to the subject matter of the Site. Users have the right to object to the processing of their personal data for marketing purposes.

IV

[Recipients of users' data]

The Administrator shall disclose users' personal data only to processors under concluded personal data processing entrustment agreements for the purpose of performing services for the Administrator, such as hosting and operating the Site, IT services, marketing and PR services, legal and consulting services.

V

[Transmission of personal data to third countries]

Personal data will not be processed in third countries.

VI

[Rights of personal data subjects]

1. (1) Every data subject shall have the right to:
   1. access - to obtain confirmation from the controller as to whether his/her personal data is being processed. If a person's data is being processed, he or she is entitled to access it and to obtain the following information: the purposes of the processing, the categories of personal data, the recipients or categories of recipients to whom the data have been or will be disclosed, the period for which the data are stored or the criteria for determining them, the right to request rectification, erasure or restriction of the processing of personal data of the data subject, and to object to such processing (Article 15 RODO);
   2. In order to exercise the aforementioned rights, the data subject should contact the controller by directing a request to the e-mail address in accordance with Section II, paragraph 2 of the Privacy Policy and inform the controller which right he or she wishes to exercise and to what extent he or she wishes to exercise it;
   3. to rectification - to request the rectification of personal data concerning her that is incorrect or the completion of incomplete data (Article 16 of the DPA);
   4. to erasure - to request the deletion of her personal data if the controller no longer has a legal basis for processing them or the data are no longer necessary for the purposes of processing (Article 17 RODO);
   5. to restrict processing - request the restriction of processing of personal data (Article 18 RODO) when:
      1. the data subject questions the accuracy of the personal data - for a period that allows the controller to verify the accuracy of the data,
      2. the processing is unlawful, and the data subject objects to the erasure of the data, requesting restriction of its use,
      3. the controller no longer needs the data, but they are needed by the data subject to establish, assert or defend claims,
      4. the data subject has objected to the processing - until it is determined whether the legitimate grounds on the part of the controller override the grounds of the data subject's objection;
   6. to data portability - to receive in a structured, commonly used, machine-readable format the personal data concerning him or her that he or she has provided to the controller, and to request that the data be sent to another controller if the data are processed on the basis of the data subject's consent or a contract with him or her, and if the data are processed by automated means (Article 20 RODO);
   7. to object - to object to the processing of his or her personal data for legitimate purposes of the controller, on grounds related to his or her particular situation, including profiling. The controller shall then assess the existence of valid legitimate grounds for processing that override the interests, rights and freedoms of data subjects, or grounds for establishing, asserting or defending claims. If, according to the assessment, the interests of the data subject outweigh the interests of the controller, the controller will be obliged to cease processing for these purposes (Article 21 of the DPA);
   8. to withdraw consent at any time and without stating a reason, but the processing of personal data carried out before the withdrawal of consent will continue to be lawful. Withdrawal of consent will cause the controller to cease processing personal data for the purpose for which the consent was given.
2. In order to exercise the above-mentioned rights, the data subject should contact, using the contact information provided, the controller and inform him of which right and to what extent he wishes to exercise it.

VII

[President of the Office for Personal Data Protection]

The data subject shall have the right to lodge a complaint with the supervisory authority, which in Poland is the President of the Office for Personal Data Protection, based in Warsaw, 2 Stawki Street, who may be contacted as follows:

1. by mail: 2 Stawki Street, 00-193 Warsaw;
2. via electronic mailbox available at:https://www.uodo.gov.pl/pl/p/kontakt;
3. by telephone: (22) 531 03 00.

VIII

[Data Protection Officer]

In any case, the data subject may also directly contact the Data Protection Officer of the controller:

1. by e-mail at the e-mail address: iod@luxtrade.pl;
2. at the above-mentioned mailing address with the subject line: Data Protection Officer.

IX

[Changes to the privacy policy]

1. The privacy policy may be supplemented or updated according to the current needs of the controller in order to provide up-to-date and reliable information to users regarding their personal data and information. Users will be notified of any changes to the privacy policy on the Site.
2. This privacy policy is effective as of 31.01.2021

X

[Legal acts cited in the clause]

1. RODO - Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 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 (Official Journal of the EU L 2016 No. 119, p. 1);
2. Article 118 et seq. of the Act of April 23, 1964. - Civil Code (i.e., Journal of Laws 2018, item 1025, as amended);
3. Article 8 of the Act of July 18, 2002 on the provision of electronic services (i.e., Journal of Laws of 2017, item 1219, as amended);
4. Article 173(2) of the Act of July 16, 2004. - Telecommunications Law (i.e., Journal of Laws of 2017, item 1907, as amended).