This document specifies the terms of processing personal data (hereinafter also referred to as “data”) and cookies in the area of the flawless.eu online store, operated via the website, available at the URL address: flawless.eu, hereinafter referred to as the “Store”.
TABLE OF CONTENTS
§1. HOW TO CONTACT THE DATA ADMINISTRATOR
§2. ON WHAT BASIS DO WE PROCESS YOUR DATA
§3. INFORMATION ON DATA PROCESSING FOR THE PURPOSE OF CONCLUSION AND PERFORMANCE OF AGREEMENTS, POSSIBLE CLAIM SECURITY AND DEFENSE AGAINST THEM
§4. INFORMATION ON DATA PROCESSING FOR THE PURPOSE OF SENDING THE NEWSLETTER
§5. INFORMATION ON DATA PROCESSING FOR THE PURPOSE OF SENDING NOTIFICATIONS
§6. INFORMATION ON DATA PROCESSING FOR THE PURPOSE OF SENDING ADVERTISEMENTS AND COMMERCIAL INFORMATION
§7. INFORMATION ON DATA PROCESSING FOR DIRECT MARKETING AND PROFILING
§8. INFORMATION ON DATA PROCESSING FOR THE PURPOSE OF ENSURING SECURITY
§9. INFORMATION ON DATA RECIPIENTS
§10. ABSOLUTE RIGHTS OF PERSONS WHOSE DATA IS PROCESSED
§11. RELATIVE RIGHTS OF PERSONS WHOSE DATA IS PROCESSED
§12. COOKIES – INTRODUCTION
§13. COOKIES OF THE DATA ADMINISTRATOR
§14. COOKIES OF THIRD PARTIES
§15. CONSENT TO THE USE AND MANAGEMENT OF COOKIES
§16. CACHE
§17. LINKS TO OTHER WEBSITES OR SOFTWARE
§18. CHANGES TO THE PRIVACY POLICY AND COOKIES
§1. HOW TO CONTACT THE DATA ADMINISTRATOR
The administrator of personal data processed within the Store is Flawless Sp. z o.o. with its registered office in Warsaw (02-797) at Aleja Komisji Edukacji Narodowej 52/89, entered into the Register of Entrepreneurs of the National Court Register under KRS number: 0000632128, NIP: 9512417736 and REGON: 365125782. You can contact the Data Administrator by e-mail: info@flawless.eu.
§2. ON WHAT BASIS DO WE PROCESS YOUR DATA
When collecting personal data, we always inform you about the legal basis for their processing. It results from the provisions of the GDPR (Regulation of the European Parliament and of the Council (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data on the free movement of such data and repealing Directive 95/46/EC – General Data Protection Regulation). When we inform you about:
• Art. 6, point 1, letter a) of the GDPR – this means that we process personal data based on the consent received,
• Art. 6, point 1, letter b) of the GDPR – this means that we process personal data because they are necessary for the performance of the contract or to take action before its conclusion, upon the request received,
• Art. 6, point 1, letter c) of the GDPR – this means that we process personal data in order to fulfill a legal obligation,
• Art. 6, point 1, letter f) of the GDPR – this means that we process personal data in order to exercise legally justified interests.
§3. INFORMATION ON DATA PROCESSING FOR THE PURPOSE OF CONCLUSION AND IMPLEMENTATION OF CONTRACTS, POSSIBLE CLAIM SECURITY AND DEFENSE AGAINST THEM
We may process personal data necessary for the performance of the contract concluded with you. However, before its conclusion, we may process personal data necessary to take action at your request. The processing of this data is based on art. 6 point 1 letter b) of the GDPR.
During the performance of the contract and after its execution, we process the personal data of its parties in order to possibly consider claims and pursue them. Our legitimate interest is, for example, the ability to respond to a possible complaint, to which we are obliged under separate provisions of civil law. In such a case, we will process personal data based on a legitimate interest, which is the defense against possible claims or their pursuit. The processing of this data is based on art. 6 point 1 letter f) of the GDPR.
We will store this data for the period necessary to achieve the specified purposes, no later than until the claims resulting from separate provisions of law expire.
You have the right to access your data, rectify it, delete it, limit its processing, the right to transfer data, and the right to lodge a complaint with the supervisory authority. In the event of data processing for the purpose specified in point 2, you also have the right to object to its processing.
Providing this data is voluntary, but failure to provide this data will prevent the conclusion of the agreement or its implementation.
The recipients of this data are: our hosting provider, e-mail service provider, IT service provider, transport service provider, accounting service provider and invoice software provider, electronic payment and banking service provider, legal, advisory and debt collection service provider and other service providers that we use for the specified purpose.
§4. INFORMATION ON DATA PROCESSING FOR THE PURPOSE OF SENDING THE NEWSLETTER
We enable you to subscribe to the list of recipients of our newsletter. If you have used
this functionality, we process your personal data precisely for the purpose of sending it. The newsletter may contain advertising, commercial or marketing content.
The processing of this data takes place on the basis of your consent and thus art. 6 point 1 letter a) of the GDPR.
You have the right to withdraw your consent at any time. However, the withdrawal of consent does not affect the lawfulness of previous data processing.
We will store your data until you withdraw your consent. If you never withdraw it, we will process your data until we stop sending the newsletter.
You have the right to access your data, rectify it, delete it, limit its processing, the right to transfer data, and the right to lodge a complaint with the supervisory authority.
Providing this data is voluntary, but failure to provide this data will prevent the newsletter from being sent.
The recipients of this data are: our hosting provider, IT service provider, e-mail service provider and newsletter sending service provider.
§5. INFORMATION ON DATA PROCESSING FOR THE PURPOSE OF SENDING NOTIFICATIONS
We enable you to subscribe to the list of recipients of our notifications, displayed via a web browser. If you have used this functionality, we process your personal data precisely for the purpose of sending it. Notifications may contain advertising, commercial or marketing content.
The processing of this data is based on your consent and therefore art. 6 point 1 letter a) of the GDPR.
You have the right to withdraw your consent at any time. However, withdrawing consent does not affect the lawfulness of previous data processing.
We will store your data until you withdraw your consent. If you never withdraw it, we will process your data until we stop sending notifications.
You can withdraw your consent to data processing in your web browser.
You have the right to access your data, rectify it, delete it, limit its processing, the right to transfer data, and the right to lodge a complaint with the supervisory authority.
Providing this data is voluntary, but failure to provide this data will prevent notifications from being sent.
The recipients of this data are: our hosting provider, advertiser and notification service provider.
§6. INFORMATION ON DATA PROCESSING FOR THE PURPOSE OF SENDING ADVERTISEMENTS AND COMMERCIAL INFORMATION
We enable you to subscribe to the list of recipients of our messages containing advertising, commercial or marketing content. If you have used this functionality, we process your personal data precisely for the purpose of sending them.
The processing of this data takes place on the basis of your consent and thus art. 6 point 1 letter a) of the GDPR.
You have the right to withdraw your consent at any time. However, the withdrawal of consent does not affect the lawfulness of previous data processing.
We will store your data until you withdraw your consent. If you never withdraw it, we will process your data until we stop sending the messages in question.
You have the right to access your data, rectify it, delete it, limit its processing, the right to transfer it, as well as the right to lodge a complaint with the supervisory authority.
Providing this data is voluntary, but failure to provide this data will prevent the newsletter from being sent.
The recipients of this data are: our hosting provider, IT service provider, e-mail service provider.
§7. INFORMATION ON DATA PROCESSING FOR DIRECT MARKETING AND PROFILE
We may process your personal data for direct marketing purposes. This happens, for example, when we respond to your message by presenting details of our offer.
For direct marketing purposes, we may use profiling, which involves automated decision-making on displaying advertisements to you. This decision is made based on the actions you take in the Store, and in particular on the basis of concluded agreements or pages viewed. In practice, profiling supports the usability of our Store, allowing us to present you with content that may potentially interest you.
The processing of this data is based on art. 6 point 1 letter f) of the GDPR.
We will store your data for the time necessary for the purpose of implementation.
You have the right to access your data, rectify it, delete it, limit its processing, the right to transfer data, the right to object to the processing of data, and the right to lodge a complaint with the supervisory authority.
You have the right not to be subject to profiling, unless you have given your consent. However, in such case, the basis for the processing of your data will be the consent granted (art. 6 point 1 letter a) of the GDPR), which you can withdraw at any time. In such case, your data will also be processed until the consent granted is withdrawn.
not providing this data is voluntary, and failure to provide this data will prevent direct marketing activities.
The recipients of this data are: our hosting provider, IT service provider, e-mail service provider, advertising service provider.
§8. INFORMATION ON DATA PROCESSING FOR THE PURPOSE OF ENSURING SECURITY
From the moment you launch our website, in order to ensure the security of services, we process the following data:
• public IP address of the device from which the query came,
• browser type and language,
• date and time of the query,
• number of bytes sent by the server,
• URL address of the previously visited page, in the event that the visit was made using this link,
• information about errors that occurred during the execution of the query.
Our legitimate interest in this processing is to keep server event logs and to secure the Store against potential hacker attacks and other abuses. This includes the possibility of determining the IP address of a person performing an unauthorized activity in the Store area, such as an attempt to break security, or publish prohibited content, or attempt to perform unauthorized activities using our servers.
The processing of this data is carried out on the basis of art. 6 point 1 letter f) of the GDPR.
We will store this data for the period necessary to achieve the specified purposes, no later than until the limitation period for claims arising from separate legal provisions.
You have the right to access your data, rectify it, delete it, limit its processing, object to its processing, and the right to lodge a complaint with the supervisory authority.
Providing this data is a condition for using the Store. Failure to provide this data will prevent you from using the Store.
The recipient of this data is our hosting provider and IT service provider.
§9. INFORMATION ABOUT DATA RECIPIENTS
When processing personal data, we use external services. Therefore, the recipients of your personal data may be third parties. When collecting personal data, we always inform about these recipients, however, due to the priority of readability of the message, we do it briefly. Therefore, we hereby explain that when we inform about individual categories of recipients, these are the following entities:
• Transport service provider / couriers: DPD Polska Sp. z o.o., ul. Mineralna 15, 02-274 Warsaw; InPost S.A., ul. Wielicka 28, 30-552 Krakow.
• IT service provider: HELLO WORLD! Sp. z o.o., ul. Twarda 18, 00-105 Warsaw.
• Hosting provider: OVH Sp. z o.o., ul. Swobodna 1, 50-088 Wrocław.
• Email service provider: Unix Storm – Michał Gottlieb, ul. Graniczna 2db/19, 54-610 Wrocław.
• Advertising service provider: Beeffective Tomasz Piotrowski, Al. Zwycięstwa 96/98/ B.2.18, 81-451 Gdynia; G&C Online Solutions Limited, Drumgora, Virginia, Cavan, A82r2v0, Ireland.
• Accounting service provider: Eip Finanse Sp. z o.o., Al. Komisji Edukacji Narodowej 52/89, 02-797 Warsaw.
• Invoice software provider: InsERT S.A., ul. Jerzmanowska 2, 54-519 Wrocław.
• Legal / advisory / debt collection service provider – these service providers are appointed individually, in the event of each need.
• Newsletter sending service provider: YouLead Sp. z o.o., ul. Wrzesińska 12 / 39, 03-713 Warsaw.
• Electronic payment service provider: PayPal (Europe) S.Ã r.l. et Cie, S.C.A., 22-24 Boulevard Royal L-2449, Luxembourg; PayU S.A., ul. Grunwaldzka 186, 60-166 Poznań.
§10. ABSOLUTE RIGHTS OF PERSONS WHOSE DATA IS PROCESSED
When we write about the rights related to the processing of your personal data, we refer to the rights described below. The possibility of using the rights below is independent of the legal basis for the processing of personal data.
Right of access to data
You have the right to obtain from us confirmation as to whether we process personal data concerning you. If so, you have the right to access this data, as well as to receive additional information about:
• the purposes of processing,
• the categories of data concerned,
• the recipients or categories of recipients to whom the data have been or will be disclosed, in particular recipients in third countries or international organisations,
• if possible, the planned period of data storage, and if this is not possible, the criteria for determining this period,
• the right to request that we rectify, delete or limit the processing of data, to object to such processing, and the right to lodge a complaint with a supervisory authority,
• the source of the data, if your data has not been collected from you,
• automated decision-making, including profiling and the principles of their making, as well as the significance and foreseeable consequences of such processing for you.
After receiving such a request, we are obliged to provide a copy of the personal data subject to processing. If such a request is received electronically and if we do not receive
we have other reservations, we will also provide information electronically.
Right to rectification of data
You have the right to demand that we immediately rectify personal data concerning you that is incorrect. Taking into account the purposes of processing, you have the right to request that incomplete personal data be supplemented, including by providing an additional statement.
Right to erasure of data (to be forgotten)
You have the right to demand that we immediately delete personal data concerning you. We are then obliged to delete personal data without undue delay if one of the following circumstances occurs:
• you have withdrawn your consent to the processing of your personal data and we have no other basis for their processing,
• you have filed an effective objection to the processing of data concerning you,
• your personal data has been processed unlawfully,
• your personal data must be deleted in order to comply with a legal obligation,
• your data has been collected in connection with the provision of information society services. The right to restrict processing
You have the right to request that we restrict processing in the following cases:
• if you dispute the accuracy of the data – for a period allowing us to verify its accuracy,
• the processing is unlawful and you object to the deletion of the data, requesting instead the restriction of its use,
• we no longer need the personal data for the purposes of processing, but you need them to establish, pursue or defend claims,
• you have objected to the processing of your data – until it is determined whether the legitimate grounds on our side override the grounds for your objection.
Automated decisions, including profiling
You have the right not to be subject to a decision that is based solely on automated processing, including profiling, and produces legal effects for you or significantly affects you in a similar way. The law does not apply if this decision:
• is necessary for the conclusion or performance of a contract between you and us,
• is permitted by EU law or the law of the Republic of Poland and which provides for appropriate measures to protect your rights, freedoms and legitimate interests, or
• is based on your express consent.
Right to lodge a complaint
You have the right to lodge a complaint in connection with the processing of your personal data with the supervisory authority: President of the Personal Data Protection Office, ul. Stawki 2, 00-193 Warsaw, tel. 22 531 03 00, fax. 22 531 03 01, e-mail: kancelaria@uodo.gov.pl.
§11. RELATIVE RIGHTS OF PERSONS WHOSE DATA ARE PROCESSED
When we write about the rights related to the processing of your personal data, we refer to the rights described below. The possibility of using them is always dependent on the legal basis for processing personal data.
Right to withdraw consent to processing
In the event that we process your personal data based on your consent, you have the right to withdraw your consent at any time. Of course, withdrawing your consent does not affect the lawfulness of the previous processing of personal data.
Right to data portability
You have the right to receive your personal data provided to us in a structured and commonly used machine-readable format. You also have the right to transmit this personal data to another controller without hindrance from us, if the processing is carried out:
• based on consent or on a contract, and
• in an automated manner.
When exercising the right to data portability, you have the right to request that the personal data be transmitted by us directly to another controller, provided that this is technically possible. This right must not adversely affect the rights and freedoms of others.
Right to object
In the event that we process your personal data on the basis of Art. 6 point 1 lit. f) GDPR, you have the right to object to the processing of this data, for reasons related to your particular situation.
Then we are no longer allowed to process this personal data, unless we prove the existence of:
• important, legally justified grounds for processing, whereby these grounds must override the interests, rights and freedoms of your person, or
• grounds for establishing, pursuing or defending claims.
Also, if you object to the processing of your personal data for direct marketing purposes, then we will not be able to process them for such purposes.
§12. COOKIE FILES – INTRODUCTION
The Store’s website uses cookies. These are commonly used, small files containing a string of characters that are sent and saved on the end device (e.g. computer, laptop, tablet, smartphone) used when visiting the Store. This information is sent to the memory of the browser used, which sends it back on the next visits to the website. We can categorize cookies with regard to
three methods of division.
In terms of the purposes of using cookies, we distinguish three categories:
• Necessary files – these files enable the website and its functionalities to function properly, e.g. authentication or security cookies. Without saving them on your device, using the website will be impossible.
• Analytical files – these files enable monitoring of opened websites, traffic sources, time spent on the website. Without saving them, using the website’s functionalities will not be limited.
• Advertising files – these files enable the display of personalized advertisements within or outside the website. Without saving them, using the website’s functionalities will not be limited.
• Social media files – these files enable the display of a fanpage within the website’s area, as well as liking it. Without saving them, using the website’s functionalities will not be limited.
• YouTube files – these files enable the display of an embedded video file. Without saving them, displaying video files will not be possible.
In terms of their validity period, we distinguish two categories of cookies:
• session cookies – existing until the end of a given session,
• persistent cookies – existing after the session ends.
In terms of distinguishing the entity administering cookies, we distinguish:
• our cookies,
• third-party cookies.
§13. DATA ADMINISTRATOR COOKIES
The cookies we administer allow for:
• access authentication,
• maintaining the session after logging in,
• securing the Store against hacker attacks,
• “remembering” the content of fields in completed forms (optional) by the browser,
• “remembering” items added to the basket by the browser.
Thanks to this, using the Store’s functionalities becomes easier and more enjoyable.
§14. THIRD-PARTY COOKIES
The use of third-party cookies is subject to the privacy and cookie policies applied by these entities.
GOOGLE
We use cookies administered by Google Inc. 1600 Amphitheatre Pkwy, Mountain View, CA 94043, United States as part of the following services:
• Google Ads – advertising files used to conduct and assess the quality of advertising campaigns implemented using the Google Ads service,
• Google Analytics – analytical files used to study user behavior and traffic and to prepare traffic statistics,
• YouTube – they allow for displaying embedded video files from YouTube.
The data collected by Google Inc. are anonymous and aggregated. In particular, they do not contain identifying features (understood as personal data) of the Store’s users. Using the above services, we collect data such as the sources of acquisition of users visiting the Store, as well as the way they behave on the Store’s website, information about the devices and browsers they use, IP address, domain, demographic data (age, gender), interests and geographic data.
More information in this regard can be found here: https://policies.google.com/technologies/cookies?hl=pl
FACEBOOK
We use files administered by Facebook Inc. 1 Hacker Way, Menlo Park, CA 94025, United States:
• Functional cookies used by Facebook Inc. 1 Hacker Way, Menlo Park, CA 94025, United States. These files can be used to connect your account on the external social networking site Facebook with your account in the Store. These files can also be used to process your actions performed using the “Share” or “Like” buttons on Facebook. The processing of these actions may be public.
• Advertising pixel tags used by Facebook Inc. 1 Hacker Way, Menlo Park, CA 94025, United States. These are elements published in digital content and enable the recording of information, e.g. about activity carried out on the website, as well as the evaluation of the effectiveness of advertisements. Management of the Facebook Inc. pixel tag. is possible via Facebook, in its user panel
More information in this regard can be found here: https://www.facebook.com/policies/cookies/
HOTJAR
We use cookies administered by Hotjar Limited, Level 2, St Julian’s Business Centre, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta. Thanks to the Hotjar tool, we analyze your activities on our website, taking into account: information about your device and browser and its language, location, as well as an anonymized IP number. We perform this analysis in order to optimize our website in terms of its usability. If you wish to object to the processing of your data for these purposes, use the link: https://www.hotjar.com/legal/compliance/opt-out.
YouLead
We use cookies administrative
ne by YouLead Sp. z o.o., ul. Wrzesińska 12 / 39, 03-713 Warsaw. These files can be used to analyze your shopping preferences and customize marketing activities on this basis, including displaying personalized ads to you. More information in this regard can be found here: https://www.youlead.pl/wp-content/uploads/2020/10/polityka-prywatno%C5%9Bci-i-plik%C3%B3w-cookies.pdf
The use of third-party cookies is subject to the privacy and cookie policies used by these entities. The current rules of third parties in this regard can be found on the websites mentioned and here: https://www.e-regulaminy.pl/biuletyn/polityki-prywatnosci-i-plikow-cookies/.
§15. CONSENT TO THE USE OF COOKIES AND THEIR MANAGEMENT
With the exception of essential cookies, their processing is based on the user’s consent.
Consent to the processing of cookies is voluntary and may be withdrawn at any time. However, please note that failure to consent to the use of certain cookies may result in limitations in the use of the Store and its functionalities, or even prevent such use.
Consent to the processing of cookies may be granted:
• using the software settings installed on the user’s telecommunications terminal device,
• using the button containing a declaration of consent to the processing of cookies or confirmation of familiarization with its terms,
• using the settings available in the website area.
§16. CACHE
When you use the Store’s website, we can automatically use the cache installed on your device. As part of local memory, it is possible to store data intersessionally, i.e. between subsequent visits to the Store’s website. The purpose of using the cache is to speed up the use of the Store by eliminating situations in which the same data would be downloaded from the Store multiple times, thus burdening the user’s internet connection. The cache may also store data such as the login password.
§17. LINKS TO OTHER WEBSITES OR SOFTWARE
The Store may contain links to other websites or software. We are not responsible for the privacy policy and cookie processing rules applicable on these websites or in this software. We recommend that you read the privacy policy and cookies of these websites or software after entering them or before installing them.
§18. CHANGES TO THE PRIVACY POLICY AND COOKIES
The privacy policy and cookies enter into force on the date of publication on the Store’s website.
The Privacy Policy and Cookies are changed by publishing its new content on the Store’s website.
We publish information about changes to the Privacy and Cookies Policy in the Store website area no later than 3 days before the date on which its new wording becomes effective.
