1. GENERAL STATEMENT
1.1 This Privacy Policy of the Internet Shop is for information purposes only, which means that it is not a source of obligations for the Service Recipients or Customers of the Internet Shop. The Privacy Policy primarily contains rules concerning the Administrator's processing of personal data in the Internet Shop, including the grounds, purposes and scope of personal data processing and the rights of data subjects, as well as information on the use of cookies and analytical tools in the Internet Shop.
1.2.The Administrator of the personal data collected via the Internet Shop is TLCS Sp. z o.o. operating under the name of TLCS Sp. z o.o. registered in the National Court Register (KRS): 0000570154, having: business address and address for delivery: ul. Serwisowa 1, 55-095 Długołęka, post office Mirków, NIP 8952049650, REGON 362190112, e-mail address: info@kiurlab.pl, contact phone number: 71 77 33 774- hereinafter referred to as the "Administrator" and being at the same time the Service Provider of the Internet Shop and the Seller.
1.3 Personal data in the Online Shop shall be processed by the Administrator in accordance with the applicable legal provisions, 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 "RODO" or "RODO Regulation". Official text of the RODO Regulation: http://eur-lex.europa.eu/legal-content/PL/TXT/?uri=CELEX%3A32016R0679
1.4 The use of the Online Shop, including making purchases, is voluntary. Similarly, the related provision of personal data by the Customer or Client using the Online Shop is voluntary, subject to two exceptions: (1) conclusion of agreements with the Administrator - failure to provide, in the cases and to the extent indicated on the website of the Internet Shop and in the Regulations of the Internet Shop and this privacy policy, personal data necessary for the conclusion and performance of a Sales Agreement or an agreement for the provision of Electronic Services with the Administrator results in the impossibility of concluding such an agreement. Providing personal data in such a case is a contractual requirement and if the data subject wishes to conclude a given agreement with the Administrator, he/she is obliged to provide the required data. Each time the scope of data required to conclude a contract is indicated beforehand on the website of the Internet Shop and in the Terms and Conditions of the Internet Shop; (2) statutory obligations of the Administrator - providing personal data is a statutory requirement resulting from generally applicable laws imposing an obligation to process personal data on the Administrator (e.g. processing of data for tax or accounting purposes), and failing to provide such data will make it impossible for the Administrator to fulfil those obligations.
1.5 The controller shall take particular care to protect the interests of the persons whose personal data it processes and shall in particular be responsible for and ensure that the data it collects are: (1) processed lawfully; (2) collected for specified, legitimate purposes and not subjected to further processing incompatible with those purposes; (3) substantively correct and adequate in relation to the purposes for which they are processed; (4) kept in a form which permits identification of data subjects for no longer than is necessary to achieve the purpose of the processing; and (5) processed in a manner which ensures appropriate security of personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, by means of appropriate technical or organisational measures.
1.6 Having regard to the nature, scope, context and purposes of the processing and the risk of violation of the rights or freedoms of natural persons of varying probability and seriousness, the Controller shall implement appropriate technical and organisational measures to ensure that the processing is carried out in accordance with this Regulation and to be able to demonstrate this. These measures shall be reviewed and updated as necessary. The Administrator shall apply technical measures to prevent the acquisition and modification by unauthorised persons, of personal data transmitted electronically.
1.7 All words, phrases and acronyms appearing in this privacy policy and beginning with a capital letter (e.g. Seller, Online Shop, Electronic Service) shall be understood in accordance with their definition contained in the Rules and Regulations of the Online Shop available on the pages of the Online Shop.
2. PERSONAL DATA PROCESSING
2.1.The controller shall be entitled to process personal data where, and to the extent that, one or more of the following conditions are met:
(1) the data subject has given his or her consent to the processing of his or her personal data for one or more specified purposes;
(2) the 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) the processing is necessary for compliance with a legal obligation incumbent on the Controller; 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.
2.2.The processing of personal data by the Controller requires in each case the existence of at least one of the grounds indicated in point. 2.1 of the Privacy Policy. The specific grounds for the Administrator's processing of the personal data of Service Recipients and Customers of the Internet Shop are indicated in the next section of the privacy policy - with reference to the given purpose of personal data processing by the Administrator.
3. PURPOSE AND SCOPE OF DATA COLLECTION AND RECIPIENTS OF THE DATA
3.1 In each case, the purpose, basis, period and scope and recipients of the personal data processed by the Administrator result from the activities undertaken by the respective Customer or Client in the Online Shop. For example, if a Customer decides to make a purchase from the Online Shop and chooses personal collection of the purchased Product instead of courier delivery, his/her 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 the delivery on behalf of the Administrator.
3.2 The Administrator may process personal data in the Online Shop for the following purposes, on the following grounds, for the following periods and to the following extent:
| Purpose of data processing | Legal basis for processing and data retention period | Scope of data processing |
| Execution of a Sales Contract or a contract for the provision of electronic services or taking action at the request of the data subject prior to entering into the aforementioned contracts | Article 6(1)(b) of the RODO Regulation (performance of a contract) The data shall be stored for the period necessary for the performance, termination or otherwise expiry of the concluded contract. | Maximum scope: name, e-mail address, contact telephone number, delivery address (street, house number, apartment number, postal code, town, country), residential/business/residential address (if different from delivery address) For Service Recipients or Clients who are not consumers, the Administrator may additionally process the company name and tax identification number (TIN) of the Service Recipient or Client. The range stated is maximum - in the case of personal collection, for example, it is not necessary to specify a delivery address |
| Direct marketing | Article 6(1)(f) of the RODO Regulation (legitimate interest of the controller) The data shall be stored for the period of existence of the legitimate interest pursued by the Administrator, but no longer than the period of limitation of claims against the data subject in respect of the Administrator's business activities. The period of limitation is determined by law, in particular the Civil Code (the basic limitation period for claims related to the conduct of business activities is three years, and for a sales contract it is two years). The controller may not process the data for direct marketing purposes in the event of an effective objection to this effect by the data subject. | E-mail address |
| Marketing | Article 6(1)(a) of the RODO Regulation (consent) Data shall be stored until the data subject has withdrawn his or her consent to further processing of his or her data for this purpose | Name, e-mail address |
| Feedback from the customer on the concluded sales contract | Article 6(1)(a) of the RODO Regulation Data shall be stored until the data subject has withdrawn his or her consent to further processing for this purpose | E-mail address |
| Keeping of tax books | Article 6(1)(c) of the RODO Regulation in conjunction with Article 86(1) of the Tax Ordinance, i.e. of 17 January 2017. (Journal of Laws of 2017, item 201) Data is retained for the period required by law requiring the Administrator to keep tax books (until the expiry of the statute of limitations on tax liability, unless otherwise provided by tax laws) | Name, residential/business/residential address (if different from delivery address), company name and tax identification number (NIP) of the Service Provider or Customer |
| Establishing, asserting or defending claims which the Administrator may have or may have against the Administrator | Article 6(1)(f) of the RODO Regulation The data shall be stored for the period of existence of the legitimate interest pursued by the Administrator, but no longer than the period of limitation of claims against the data subject in respect of the Administrator's business activities. The period of limitation shall be determined by the provisions of law, in particular the Civil Code (the basic limitation period for claims related to the conduct of business activities is three years and for a sales contract it is two years) | Name, e-mail address, contact telephone number, delivery address (street, house number, apartment number, postal code, town, country), residential/business/residential address (if different from delivery address) For Service Recipients or Clients who are not consumers, the Administrator may additionally process the company name and tax identification number (TIN) of the Service Recipient or Client. |
4.1 For the proper functioning of the Online Shop, including the performance of concluded Sales Agreements, it is necessary for the Administrator to use the services of external entities (such as e.g. software provider, courier, or payment processor). The Administrator shall only use the services of such processors who provide sufficient guarantees of the implementation of appropriate technical and organisational measures so that the processing meets the requirements of the RODO Regulation and protects the rights of the data subjects.
4.2.The transfer of data by the Administrator does not take place in every case and not to all the recipients or categories of recipients indicated in the privacy policy - the Administrator transfers data only if it is necessary for the purpose of processing the personal data in question and only to the extent necessary for its fulfilment. For example, if the Customer uses personal collection, his/her data will not be transferred to the carrier cooperating with the Administrator.
4.3.The personal data of Service Recipients and Customers of the Online Shop may be communicated to the following recipients or categories of recipients:
4.3.1. carriers / forwarders / courier brokers - in case of a Customer who uses the online shop's method of Product delivery by mail or courier, the Administrator shall make the collected personal data of the Customer available to a selected carrier, forwarder or broker executing the shipment on behalf of the Administrator to the extent necessary to complete the delivery of the Product to the Customer.
4.3.2. entities processing electronic or credit card payments - in the case of a Customer who uses the electronic or credit card payment method in the Internet Shop, the Administrator shall make the collected personal data of the Customer available to a selected entity processing the aforementioned payments in the Internet Shop on the order of the Administrator to the extent necessary to process the payment made by the Customer.
4.3.3. provider of an opinion poll system - in the case of a Customer who agreed to express his or her opinion on a Sales Agreement concluded, the Administrator shall make the collected personal data of the Customer available to a selected entity providing a system of opinion polls on Sales Agreements concluded at the Internet Shop to the extent necessary for the Customer to express his or her opinion by means of the opinion poll system.
4.3.4. service providers supplying the Administrator with technical, IT and organisational solutions enabling the Administrator to conduct its business activity, including the Internet Shop and the Electronic Services provided by means of it (in particular, computer software providers for running the Internet Shop, e-mail and hosting providers and providers of business management and technical support software to the Administrator) - the Administrator shall make the collected personal data of the Customer available to a selected provider acting on its order only in the case and to the extent necessary to perform the given purpose of data processing in accordance with this Privacy Policy.
4.3.5. accounting, legal and advisory service providers providing accounting, legal or advisory support to the Administrator (in particular an accounting office, a law firm or a debt collection agency) - the Administrator shall make the collected personal data of the Customer available to the selected provider acting on its behalf only if and to the extent necessary to achieve the given purpose of the data processing in accordance with this Privacy Policy.
5. PROFILING IN THE WEBSHOP
5.1 The RODO Regulation requires the Controller to provide information on automated decision-making, including profiling as referred to in Article 22(1) and (4) of the RODO Regulation, and, at least in these cases, relevant information on the modalities of such decision-making, as well as on the significance and the envisaged consequences of such processing for the data subject. With this in mind, the Controller provides information on possible profiling in this section of the privacy policy.
5.2 The Administrator may use profiling on the Online Store for direct marketing purposes, but the decisions made on its basis by the Administrator do not concern the conclusion or refusal of a Sales Agreement or the possibility of using Electronic Services on the Online Store. The effect of the use of profiling in the Online Shop may be, for example, to grant a person a discount, send him/her a discount code, remind him/her of unfinished purchases, send him/her a proposal of a Product that may correspond to the person's interests or preferences or offer better conditions compared to the standard offer of the Online Shop. Despite the profiling, it is up to the individual to decide freely whether they want to take advantage of the discount or better conditions received in this way and make a purchase from the Online Shop.
5.3 Profiling in the Online Shop involves the automatic analysis or prediction of a person's behaviour on the website of the Online Shop, e.g. by adding a specific Product to the basket, browsing the page of a specific Product in the Online Shop, or by analysing the previous history of purchases made in the Online Shop. The condition for such profiling is that the Administrator is in possession of the person's personal data in order to be able to subsequently send the person, for example, a discount code.
5.4 The data subject shall have the right not to be subject to a decision which is based solely on automated processing, including profiling, and which produces legal effects in relation to the data subject or similarly significantly affects the data subject.
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 his/her personal data, rectification, erasure ("right to be forgotten") or restriction of processing, and has the right to object to processing, and has the right to portability of his/her data. The detailed conditions for exercising the rights indicated above are indicated in Articles 15-21 of the RODO Regulation.
6.2 Right to withdraw consent at any time - the person whose data is processed by the Controller on the basis of the consent given (on the basis of Article 6(1)(a) or Article 9(2)(a) of the RODO Regulation), then he/she has the right to withdraw consent at any time without affecting the lawfulness of the processing carried out on the basis of the consent before its withdrawal.
6.3 Right to lodge a complaint to the supervisory authority - the person whose data is processed by the Controller has the right to lodge a complaint to the supervisory authority in the manner and mode specified in the provisions of the RODO Regulation and Polish law, in particular the Personal Data Protection Act. The supervisory authority in Poland is the President of the Office for Personal Data Protection.
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 the processing of personal data concerning him or her based on Article 6(1)(e) (public interest or tasks) or (f) (legitimate interest of the controller), including profiling on the basis of these provisions. In such a case, the controller shall no longer be allowed to process these personal data unless the controller demonstrates the existence of 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 claims.
6.5 Right to object to direct marketing - where personal data are processed for the purposes of direct marketing, the data subject has the right to object at any time to the processing of personal data concerning him or her for such marketing, including 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, the Administrator may be contacted by sending an appropriate message in writing or by e-mail to the Administrator's address indicated at the beginning of the privacy policy or by using the contact form available on the website of the Internet Shop.
7. COOKIES IN THE ONLINE SHOP, USAGE DATA AND ANALYTICS
7.1 Cookies are small pieces of information in the form of text files which are sent by a server and stored on the website of the Internet Shop (e.g. on the hard drive of a computer, laptop or smartphone memory card - depending on the device used by the visitor to our Internet Shop). Detailed information on cookies as well as the history of their creation can be found, among others, here: https://en.wikipedia.org/wiki/HTTP_cookie.
7.2 The Administrator may process data contained in Cookies when visitors use the website of the Internet Shop for the following purposes:
7.2.1. identifying Customers as logged in to the Internet Shop and showing that they are logged in;
7.2.2. remembering Products added to the shopping cart for the purpose of placing an Order;
7.2.3. remembering data from completed Order Forms, surveys or login data to the Internet Shop; 2.4. adaptation of the content of the Internet Shop to the individual preferences of the Customer (e.g. as regards colours, font size, page layout) and optimisation of the use of the Internet Shop pages;7.5. keep anonymous statistics showing the manner of use of the Internet Shop website;
7.2.6. remarketing, i.e. study of the behavioural characteristics of visitors to the Internet Shop 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 advertisements tailored to their expected interests, also when they visit other websites in the advertising network of Google Inc. and Facebook Ireland Ltd
7.3 By default, most web browsers available on the market accept the storing of cookies. You are able to determine the conditions for the use of cookies via the settings of your own browser. This means that you can, for example, partially restrict (e.g. temporarily) or completely disable the possibility of storing cookies - in the latter case, however, this may affect some of the functionality of the Internet Shop (for example, it may not be possible to follow the path of the Order through the Order Form due to the Products not being remembered in the shopping cart during the consecutive steps of placing the Order).
7.4 Your browser's settings for cookies are relevant to your consent to the use of cookies by our Online Shop - in accordance with the regulations, such consent can also be expressed through your browser settings. In the absence of such consent, the cookie settings of your Internet browser must be changed accordingly.
7.5 Detailed information on how to change the settings for cookies and how to delete them yourself in the most popular web browsers is available in the help section of your browser and on the following pages (just click on the link): in Chrome in Firefox in Internet Explorer in Opera in Safari in Microsoft Edge
7.6 The Administrator may use Google Analytics, Universal Analytics services on the Online Shop provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. These services help the Administrator to analyse traffic on the Online Shop. The data collected is processed as part of the above services in an anonymised manner (this is so-called exploitation data, which prevents the identification of the person) to generate statistics to help administer the Online Shop. This data is aggregated and anonymous, i.e. it does not contain identifying characteristics (personal data) of persons visiting the website of the Internet Shop. When using the above services in the Internet Shop, the Administrator collects such data as the source and medium of obtaining visitors to the Internet Shop and the manner of their behaviour on the website of the Internet Shop, information on 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 Google Analytics from providing information about his or her activity on the website of the Online Shop - for this purpose, you can install a browser add-on provided by Google Inc. available here: https://tools.google.com/dlpage/gaoptout?hl=pl.
7.8 The Administrator may use on the Online Shop the Facebook Pixel service provided by Facebook Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland). This service helps the Administrator to measure the effectiveness of advertisements and to find out what actions visitors to the Online Shop take, and to display tailored advertisements to those visitors. You can find detailed information about the operation of Facebook Pixel at the following web address: https://www.facebook.com/business/help/742478679120153?helpref=page_content.
7.9 You can manage the operation of the Facebook Pixel via the ad settings in your Facebook.com account: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen.
8. FINAL STATEMENT
8.1 The Internet Shop may contain links to other websites. The Administrator persuades to familiarise oneself with the privacy policy set out there after visiting other websites. This privacy policy applies only to the Administrator's Internet Shop.