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Privacy policy for website regulations (information services only)
I
[Content of the administrator's privacy policy]
  1. The administrator's privacy policy is information regarding the processing of personal data and other information regarding users of the website www.luxtrade.pl (hereinafter referred to as the "Website"). In this privacy policy, the controller has also included all information that data subjects should receive in accordance with the GDPR).
  2. The privacy policy contains information on the processing of data obtained by the Website. 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 acts of Polish law, as well as European Union law, in particular GDPR (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons in relating to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC).
II
[Data of the administrator]
  1. The administrator of personal data of Website users is: LUXTRADE spółka z ograniczoną odpowiedzialnością spółka komandytowa with its registered office at ul. Rybnicka 13,43-200 Pszczyna, KRS 0000869315, NIP: 6381825171, REGON: 367781154, e-mail: kontakt@luxtrade.pl (name of the administrator, address of its registered office, designation in accordance with the register of entrepreneurs) You can contact the data administrator:
    1. at the correspondence address: LUXTRADE SP. Z O.O. SP.K. 43-200 Pszczyna ul. Rybnicka 13
    2. at the e-mail address: kontakt@luxtrade.pl.
    2. The Administrator undertakes to keep personal data confidential and properly secure it.
III
[Purposes, legal basis and data processing time]
  1. Site Operation
    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: computer IP address, information contained in cookies or other similar technologies, session data, web browser data, device data, data regarding activity on the Website, 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 tailored product and service offerings.
    2. Placing an order via the Website
      1. In order to perform the contract, the service provider processes personal data of users placing an order via the Website, i.e. e-mail address, name, surname, postal code of the town, city, street along with the house and apartment number, telephone number. In the course of fulfilling the placed order, the service provider may process a number of other information, including information about the user's use of services, cookies or other similar technologies, and information about devices.
      2. These data are processed in accordance with Art. 6 section 1 letter b GDPR in order to provide services, i.e. a contract for the provision of electronic services in accordance with the regulations availablehere, and are processed for the time necessary to perform the contract, and after that for a period corresponding to the limitation period for claims. Unless a specific provision provides otherwise, the limitation period is six years, and for claims for periodic benefits and claims related to running a business - three years.
    3. These data are processed in accordance with Art. 6 section 1 letter b GDPR, in order to provide the Website's service, i.e. a contract for the provision of electronic services in accordance with the regulations available here and in accordance with Art. 6 section 1 letter a GDPR in connection with consent to the use of specific cookies or other similar technologies expressed by appropriate settings of the web browser in accordance with the Telecommunications Law or in connection with consent to geolocation. The data is processed until the user stops using the Website.
    4. Complaints:
    5. In order to consider complaints, the service provider processes personal data of users submitting complaints, in particular e-mail address, name, content of the complaint, circumstances of the event giving rise to the complaint, information obtained in the course of considering the complaint, including explaining the event giving rise to it. In the course of considering a complaint, the service provider may process a number of other information, including the user's name and surname, information about the user's use of services, cookies or other similar technologies, and information about devices.
    1. These data are processed in accordance with Art. 6 section 1 letter b GDPR in order to provide services, i.e. contracts for the provision of electronic services in accordance with the regulations available here, and are processed for the time necessary to consider the complaint and no longer than 3 months after the end of the complaint procedure for archiving purposes in the event of the need to defend against possible claims against the service provider in accordance with the information provided below.
  2. Explanatory proceedings, pursuing claims
    1. In the event of undertaking an investigation regarding a possible violation of the provisions of the regulations or legal provisions, principles of social coexistence or good manners, proceedings to pursue claims by the administrator or by other users or entities, defense against claims of users or other entities, the administrator may process personal data of specific users until the end of the ongoing proceedings and until the expiry of the limitation period for the administrator's claims against the user, which is usually 3 years in accordance with the Civil Code, but in special cases provided for by law, it may be longer.
    2. If personal data will be processed in order to pursue claims of other users, these data may be made available for this purpose to another user or entity or to a public authority authorized by law, e.g. courts, police, prosecutor's office.
    3. These data will then be processed, including made available in accordance with Art. 6 section 1 letter c GDPR, i.e. in order to fulfill the obligation arising from the legal provisions regarding the obligation to consider complaints, in accordance with the Act on the provision of electronic services or in accordance with Art. 6 section 1 letter f GDPR, i.e. in the legitimate interest of the administrator consisting in pursuing claims against the user. The legitimate interest of the administrator will then override the rights and freedoms of the service recipient.
  3. Statistics of using services
    1. In order to improve the quality of its services, the administrator processes statistical information regarding the use of the Website, including information about the session, IP number, amount of time spent on individual pages and subpages, use of individual service functionalities, information about the device and web browser. 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. These data are processed in accordance with Art. 6 section 1 letter f GDPR in the legitimate interest of the administrator consisting in facilitating the use of the Website, improving the quality and functionality of the services provided, and the processing of this data does not violate the rights and freedoms of users. Information about users is not used for any additional purposes, and due to the specificity of the website service, customizing the way the website content is displayed, facilitating the use of the website and improving the quality of services provided on the website is not only a market standard, but also users' expectations towards suppliers websites.
    3. Moreover, the user may withdraw consent at any time by changing the web browser settings regarding the admissibility of using cookies or other similar technologies.
    4. This data is processed as part of the administrator's ongoing activities, but no longer than 60 days from receiving the information. After this time, the administrator may further process general statistical data, which will be devoid of any information regarding 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 decision-making scope. The administrator will no longer use them, but will have potential access to them until they are removed by the provider of the above tools.
  4. Marketing and PR activities of the administrator

    The administrator may post marketing information about his products or services on the Website. This content is displayed by the administrator in accordance with Art. 6 section 1 letter f GDPR, in accordance with the legitimate interest of the administrator consisting in publishing content related to the services provided and the content of promotional 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 similar content, and sometimes they even expect it or it is their direct purpose of visiting the Website.

  5. Marketing activities for other products or services
    1. The Administrator may also post marketing information regarding the products or services of its contractors with whom it has concluded a cooperation agreement in the field of marketing.
    2. This content is displayed by the administrator in accordance with Art. 6 section 1 letter f GDPR, in accordance with the legitimate interest of the administrator consisting in marketing activities of products or services of its contractors. At the same time, this action does not violate the rights and freedoms of users, in particular due to the sporadic nature of these actions, and users expect to receive similar content due to the topic of the Website. The user has the right to object to the processing of his or her personal data for marketing purposes.
IV
[Recipients of user data]

The administrator discloses users' personal data only to processing entities under concluded contracts entrusting the processing of personal data in order to provide services to the administrator, e.g. hosting and operating the Website, IT services, marketing and PR services, legal and advisory services.

V
[Transfer of personal data to third countries]

Personal data will not be processed in third countries.

VI
[Rights of persons whose personal data concern]
  1. 1. Every data subject has the right:
    1. access – obtaining confirmation from the administrator whether her personal data is being processed. If data about a person is processed, he or she is entitled to access them and obtain the following information: about the purposes of processing, categories of personal data, recipients or categories of recipients to whom the data have been or will be disclosed, about the period of data storage or about the criteria for determining them, on the right to request rectification, deletion or limitation of the processing of personal data of the data subject, and to object to such processing (Article 15 of the GDPR);
    2. To exercise the above-mentioned rights, the data subject should contact the administrator by sending a request to the e-mail address in accordance with point II, section 2 of the Privacy Policy and inform him which right he wants to exercise and to what extent he wants to exercise it;
    3. to rectify - request the rectification of incorrect personal data concerning him or her or the completion of incomplete data (Article 16 of the GDPR);
    4. to delete data - request the deletion of personal data if the administrator no longer has a legal basis for their processing or the data is no longer necessary for the purposes of processing (Article 17 of the GDPR);
    5. to limit processing - request to limit the processing of personal data (Article 18 of the GDPR), when:
      1. the data subject disputes the accuracy of the personal data - for a period enabling the controller to check the accuracy of the data,
      2. the processing is unlawful and the data subject objects to their deletion and requests restriction of their use,
      3. the controller no longer needs this data, but it is needed by the data subject to establish, pursue or defend claims,
      4. the data subject has objected to the processing - until it is determined whether the legitimate grounds of the controller override the grounds for the data subject's objection;
    6. to transfer data - to receive personal data concerning him or her in a structured, commonly used and machine-readable format, which he or she has provided to the controller, and to request that these data be sent to another controller if the data is processed on the basis of the data subject's consent or a contract with him or her contained and if the data are processed in an automated manner (Article 20 of the GDPR);
    7. to object - to object to the processing of her personal data for the legally justified purposes of the administrator, for reasons related to her particular situation, including profiling. The controller then assesses the existence of valid legitimate grounds for processing, overriding the interests, rights and freedoms of data subjects, or grounds for establishing, pursuing or defending claims. If, according to the assessment, the interests of the data subject are more important than the interests of the controller, the controller will be obliged to stop processing data for these purposes (Article 21 of the GDPR);
    8. to withdraw consent at any time and without giving reasons, but the processing of personal data carried out before the withdrawal of consent will still remain lawful. Withdrawal of consent will result in the administrator ceasing to process personal data for the purpose for which the consent was expressed.
  2. To exercise the above-mentioned rights, the data subject should contact the controller using the provided contact details and inform him which right he wants to exercise and to what extent.
VII
[President of the Personal Data Protection Office]

The data subject has the right to lodge a complaint with the supervisory authority, which in Poland is the President of the Personal Data Protection Office with its registered office in Warsaw, ul. Stawki 2, which can be contacted as follows:

  1. by post: ul. Stawki 2, 00-193 Warszawa;
  2. via the electronic inbox available at https://www.uodo.gov.pl/pl/p/kontakt;
  3. by phone: (22) 531 03 00.
VIII
[Data Protection Officer]

In any case, the data subject may also contact the controller's data protection officer directly:

  1. by e-mail at the following e-mail address: iod@luxtrade.pl;
  2. to the above correspondence address with the note: Data Protection Inspector.
IX
[Privacy policy changes]
  1. The privacy policy may be supplemented or updated in accordance with the administrator's current needs in order to provide users with current and reliable information regarding their personal data and information about them. Users will be informed about any changes to the privacy policy on the Website.
  2. This privacy policy is valid from January 31, 2021
X
[Legal acts referred to in the clause]
  1. GDPR - 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 (OJ EU L 2016 No. 119, p. 1);
  2. art. 118 et seq. of the Act of April 23, 1964 - Civil Code (consolidated text: Journal of Laws of 2018, item 1025, as amended);
  3. art. 8 of the Act of 18 July 2002 on the provision of electronic services (consolidated text: Journal of Laws of 2017, item 1219, as amended);
  4. art. 173 section 2 of the Act of July 16, 2004 - Telecommunications Law (consolidated text: Journal of Laws of 2017, item 1907, as amended)

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