Privacy Policy

PRIVACY POLICY

 

I. General Provisions

 

The Administrator of the personal data of the users of the website located under the domain www.en.theraw.net is RAW Damian Wasyl, Beata Wołoszyn spółka jawna 22-600 Tomaszów Lubelski ul. Ściegiennego 55, entered in the National Register of Entrepreneurs kept by the Sąd Rejonowy Lublin Wschód w Lublinie with headquarters in Świdniku, VI Economic Department of the National Court Register, KRS: 0000956483, NIP: 921 204 42 54.

The purpose of the Policy is to define the actions taken regarding personal data collected through the Administrator's website and related services and tools used by its users, as well as in the context of concluding and performing contracts outside the website.

In the event of necessity, the provisions of this Policy may be subject to change. Any change will be communicated to users by announcing the new content of the Policy, and in the case of a database of individuals who have consented to the processing of data by email or have provided email data in the execution of contracts, they will also be notified of the change by email.

 

 

II. Personal data processing in connection with the use of the store


In connection with the User's use of the Store, the Administrator collects data to the extent necessary to provide the services offered, as well as information about the User's activity in the Store. Detailed rules and purposes for processing personal data collected while using the Store by the User are described below.

 

 

III. Objectives and legal basis for data processing


USE OF THE STORE

 

Personal data of all persons using the Store (including the IP address or other identifiers and information collected via cookies or other similar technologies) are processed by the Administrator:

  • in order to provide services electronically in the scope of making content collected in the Store available to Users, providing contact forms - then the legal basis for processing is the necessity of processing to perform the contract (art. 6 paragraph 1 letter b of the GDPR);
  • to support purchases made without registering in the Store - then the legal basis for processing is the necessity of processing to perform the contract (art. 6 paragraph 1 letter b of the GDPR);
  • to handle complaints - then the legal basis for processing is the necessity of processing to perform the contract (art. 6 paragraph 1 letter b of the GDPR);
  • for analytical and statistical purposes - then the legal basis for processing is the justified interest of the Administrator (art. 6 paragraph 1 letter f of the GDPR) consisting in conducting analyzes of Users' activity as well as their preferences in order to improve the functionalities and services provided;
  • in order to possibly determine and assert claims or defend against them - the legal basis for processing is the justified interest of the Administrator (art. 6 paragraph 1 letter f of the GDPR) consisting in the protection of his rights;
  • for Administrator's marketing purposes

 

PLACING ORDERS

 

Placing an order (purchase of a good or service) by a Store User is associated with processing of his personal data. Providing data marked as mandatory is required to accept and process the order, and failure to do so results in the lack of its implementation. Providing other data is optional.

Personal data is processed:

  • in order to process the order placed - the legal basis for processing is the necessity of processing to perform the contract (art. 6 paragraph 1 letter b of the GDPR); in the scope of optional data, the legal basis for processing is consent (art. 6 paragraph 1 letter a GDP)
  • in order to implement the statutory obligations incumbent on the Administrator, resulting in particular from tax and accounting regulations - the legal basis for processing is the legal obligation (art. 6 paragraph 1 letter c of the GDPR);
  • for analytical and statistical purposes - the legal basis for processing is the Administrator's justified interest (art. 6 paragraph 1 letter f GDP) consisting in conducting analyzes of Users' activities in the Store, as well as their shopping preferences in order to improve the functionalities used;
  • in order to possibly determine and assert claims or defend against them - the legal basis for processing is the Controller's legitimate interest (art. 6 paragraph 1 letter f GDP) consisting in the protection of his rights.

 

CONTACT FORMS

 

Administrator provides the possibility of contacting him using electronic contact forms as well as via e-mail address or other forms of communication indicated on the Store's website. Using the form or making contact via e-mail address or other forms of communication indicated on the Store's website requires providing personal data necessary to contact the User and answer the inquiry. The User may also provide other data to facilitate contact or service the inquiry. Providing data marked as mandatory is required in order to accept and handle the inquiry, and failure to do so results in the inability to handle. Providing other data is voluntary.

Personal data is processed:

  • to identify the sender and handle his inquiry sent via the provided form - the legal basis for processing is the necessity of processing to perform the service contract ( 6 paragraph 1 letter b of the GDPR);
  • for analytical and statistical purposes - the legal basis for processing is the legitimate interest of the Administrator ( 6 paragraph 1 letter f GDPR) consisting in keeping statistics of inquiries submitted by Users via the Store in order to improve its functionality.

 

 IV. Marketing


MARKETING OBJECTIVES

 

The Administrator processes Users' personal data in order to carry out marketing activities that may consist of:

  • displaying marketing content relevant to the User's interests (behavioral advertising);
  • sending e-mail notifications about interesting offers or content, which in some cases contain commercial information;

 

DIRECT MARKETING

 

If the User has agreed to receive marketing information via e-mail, the User's personal data will be processed for the purpose of sending such information. The basis for data processing is the legitimate interest of Administrator consisting in sending marketing information within the limits of consent given by the User (direct marketing). The User has the right to object to data processing for the purposes of direct marketing, including profiling. The data will be stored for this purpose for the duration of the legally legitimate interest of Administrator, unless the User objects to receiving marketing information.

 

 V. Newsletter


Administrator provides the newsletter service on the terms specified in the regulations to persons who have provided their e-mail address for this purpose. Providing data is required to provide the newsletter service, and failure to provide it results in the inability to send it.

Personal data is processed:

  • in order to provide the newsletter sending service - the legal basis for processing is the necessity of processing to perform the contract (Article 6 paragraph 1 letter b of the GDPR);
  • in the case of sending marketing content to the User as part of the newsletter - the legal basis for processing, including profiling, is the legitimate interest of Administrator (Article 6 paragraph 1 letter f of the GDPR) in connection with the consent expressed to receive the newsletter;
  • for analytical and statistical purposes - the legal basis for processing is Administrator's legitimate interest (Article 6 paragraph 1 letter f of the GDPR) consisting in conducting analyzes of Users' activity on a given Website in order to improve the functionalities used;
  • in order to possibly establish and pursue claims or defend against them - the legal basis for processing is the legitimate interest of Administrator (Article 6 paragraph 1 letter f of the GDPR).

 

VI. Social media

 

Administrator processes the personal data of Users visiting the Administrator's profiles in social media (Facebook, Pinterest, Instagram, YouTube, Twitter). These data are processed only in connection with keeping the profile, including to inform Users about the Administrator's activity and to promote various types of events, services and products, as well as to communicate with users through the functionalities available on social media. The legal basis for the processing of personal data by the Administrator for this purpose is its legitimate interest (Article 6 paragraph 1 letter f of the GDPR) consisting in promoting its own brand and building and maintaining a brand-related community.

There are integrated social media plugins on the Store's website. 

Plug-ins, the so-called plug-ins of social networks, incl. Facebook, Instagram, and others may be on the Store's website. The related services are provided respectively by:

  • Facebook and Instagram are operated by Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbor, Dublin 2 and Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA Facebook;



VII. Cookies and similar technology 



"SERVICE" COOKIES

 

The Administrator uses the so-called service cookies primarily to provide the User with services provided electronically and to improve the quality of these services. Therefore, the Administrator and other entities providing analytical and statistical services to him use cookies, storing information or gaining access to information already stored in the User's telecommunications terminal device (computer, telephone, tablet, etc.). Cookies used for this purpose include:

  • cookies with data entered by the User (session ID) for the duration of the session (user input cookies);
  • authentication cookies used for services that require authentication for the duration of the session (authentication cookies);
  • cookies used to ensure security, e.g. used to detect fraud in the field of authentication (user centric security cookies);
  • session cookies of multimedia players (e.g. flash player cookies), for the duration of the session (multimedia player session cookies);
  • persistent cookies used to personalize the User interface for the duration of the session or a little longer (user interface customization cookies),
  • cookies used to remember the contents of the basket for the duration of the session (shopping cart cookies);

To collect statistics, Administrator uses the Google Analytics product, thus the data of the User visiting the Website will be obtained by Google, 1600 Amphitheater Parkway Mountain View, CA 94043 United States. Google is certified under the Privacy Shield program. As part of the agreement between the US and the European Commission, the latter has established an adequate level of data protection in the case of companies certified by the Privacy Shield. It is possible to block Google Analytics access to the User's data after the user installs the plugin in the browser at the link: https://tools.google.com/dlpage/gaoptout/. If you are interested in the details related to data processing as part of Google Analytics, we encourage you to read the explanations prepared by Google: https://policies.google.com/privacy?hl=pl.

 

“MARKETING” COOKIES

 

The Administrator also uses cookies for marketing purposes, including in connection with targeting behavioral advertising to Users. For this purpose, the Administrator stores information or gains access to information already stored in the User's telecommunications terminal device (computer, telephone, tablet, etc.). The use of cookies and personal data collected through them for marketing purposes requires the consent of the User. This consent may be expressed through the appropriate configuration of the browser, and may also be withdrawn at any time, in particular by clearing the cookie history and disabling cookies in the browser settings.

 

GOOGLE ADS, FACEBOOK PIXEL

 

Store's website uses the Google Ads program.

Google Ads is a program of Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, United States ("Google"). As part of Google Ads, the Administrator uses the so-called conversion tracking.

Conversion cookies are stored based on art. 6 paragraph 1 letter f of the GDPR. The website operator has a legitimate interest in analyzing user behavior to optimize both its website and its advertising.

In order to conduct effective marketing campaigns and promotions of Goods sold by Administrator through the Online Store, Administrator uses the "Facebook Pixel" option, which is provided by the Facebook social network operated by Facebook Inc., 1601 S. California Ave., Palo Alto, CA 94304 , USA or, for EU residents, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland ("Facebook").

 

 VIII. Period of processing of the personal data


We will process personal data for the duration of the contract and the time necessary to demonstrate performance of the contract, i.e. for the duration of the limitation period for claims.

 

IX. User's entitlements


Data subjects have the following rights:

  1. The right to information on the processing of personal data - the Administrator provides information on the processing of personal data, including primarily the purposes and legal grounds for processing, the scope of data held, entities to whom personal data is disclosed and the planned date of their removal;
  2. The right to obtain a copy of the data - the Administrator provides a copy of the processed data regarding the person making the request;
  3. Right to rectification - the Administrator removes any incompatibilities or errors regarding personal data being processed, and supplements or updates them if they are incomplete or have changed;
  4. The right to delete data (the so-called right to forget) - is the basis for requesting the deletion of data whose processing is no longer necessary to achieve any of the purposes for which it was collected;
  5. The right to limit processing - the Administrator ceases to carry out operations on personal data, with the exception of operations to which the data subject has consented and their storage, in accordance with the adopted retention rules, or until the reasons for limiting data processing cease (e.g. a decision will be issued supervisory authority authorizing further processing of data);
  6. The right to transfer data - to the extent that data is processed in connection with the concluded contract or expressed consent, the Administrator issues data provided by the person to whom they relate, in a format that can be read by a computer. It is also possible to request that the data be sent to another entity - provided that both the Administrator and another entity to which the data are sent have appropriate technical conditions enabling such transmission;
  7. The right to object to the processing of data for marketing purposes - the data subject may at any time object to the processing of personal data for marketing purposes, without the need to justify such an objection;
  8. The right to object to other purposes of data processing - the data subject may at any time object to the processing of personal data on the basis of the justified interest of the Administrator (e.g. for analytical or statistical purposes or for reasons related to the protection of property). An objection in this respect should contain a justification and is subject to the Administrator's assessment;
  9. The right to withdraw consent - if the data are processed on the basis of consent, the data subject has the right to withdraw it at any time, which, however, does not affect the lawfulness of the processing carried out before the withdrawal of this consent;
  10. Right to complain - if it is considered that the processing of personal data violates the provisions of the GDPR or other provisions regarding the protection of personal data, the data subject may submit a complaint to the President of the Office for Personal Data Protection.

An application regarding the exercise of the rights of data subjects, together with an indication of which request we make, can be submitted:

  • in writing to the address of the seat of RAW Damian Wasyl, Beata Wołoszyn spółka jawna, 22-600 Tomaszów Lubelski, ul. Piotra Ściegiennego 55.
  • by Administrator’s email: contact@theraw.net

If the Administrator will not be able to determine the content of the request or identify the person submitting the application based on the application, he will ask the applicant for additional information.

Answers to applications will be given within one month of receipt. If it is necessary to extend this period, the Administrator will inform the applicant about the reasons for such extension.

The answer will be given to the e-mail address from which the application was sent, and in the case of applications sent by letter, by ordinary letter to the address indicated by the applicant, unless the content of the letter indicates the desire to receive feedback to the e-mail address (in this case you must provide an email address).

  

X. Data recipients


Using some of the Store's services may involve sharing the Customer's personal data with other entities. If, as a result of the above, personal data is transferred to another entity, the processing of personal data will be subject to the privacy policy applied by such entity. The store may share the collected data with the following entities:
• payment operators in order to make electronic payments,
• courier companies, including in order to carry out the shipment,
• producers of products offered by the Store in order to implement customer complaints,
• entities providing system support to operate the website and the sales system, e.g. Shopify International Ltd. Attn: Data Protection Officer c/o Intertrust Ireland 2nd Floor 1-2 Victoria Buildings Haddington Road Dublin 4, D04 XN32 Ireland
• entities providing technological solutions for mailing service.
• entities supporting the promotion of offers, cooperate as part of marketing campaigns.
In addition, the information provided by the Customer may be made available to competent public authorities, if required by applicable law. Credit institutions, for the proper provision of installment sales, with the help of which the Store conducts a credit assessment / uses a scoring procedure. 

 

XI. Security of the personal data


Administrator conducts a risk analysis on an ongoing basis to ensure that personal data is processed by him in a safe manner - ensuring, above all, that only authorized persons have access to the data and only to the extent that it is necessary due to the not the job. The administrator makes sure that all operations on personal data are recorded and performed only by authorized employees and colleagues.

Administrator shall take all necessary steps to ensure that its subcontractors and other cooperating entities guarantee the application of appropriate security measures in each case when they process personal data on behalf of the Administrator.

 

 XII. Contact details


Contact with the Administrator is possible in writing to the address of the seat of Administrator at: RAW Damian Wasyl, Beata Wołoszyn spółka jawna, 22-600 Tomaszów Lubelski, ul. Piotra Ściegiennego 55 or by Administrator’s email: contact@theraw.net