Privacy Policy

1. This Privacy Policy sets out the rules for processing personal data obtained through the online store at www.adorome.pl (the “Online Store”).

2. The owner of the Online Store and the controller of personal data is HK Distribution Sp. z o.o., with its registered office at ul. Pory 78, 02-757 Warsaw, Poland, NIP (tax identification number) 5214140681, REGON (business register number) 543227625, entered in the register of entrepreneurs maintained by the District Court for the Capital City of Warsaw in Warsaw, 13th Commercial Division of the National Court Register, under KRS number 0 0001204576, with share capital of PLN 5,000; email: info@adorome.pl, which is also the owner of the Online Store.

3. Personal data collected by HK Distribution Sp. z o.o. through the Online Store is processed 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 (the General Data Protection Regulation, or “GDPR”).

4. HK Distribution Sp. z o.o. takes particular care to respect the privacy of Customers visiting the Online Store.

§ 1 Types of data processed, purposes and legal bases

1. HK Distribution Sp. z o.o. collects information about individuals entering into a legal transaction not directly related to their business or professional activity, individuals conducting business or professional activities in their own name, and individuals representing legal persons or organisational units without legal personality to which the law grants legal capacity, collectively referred to as “Customers”.

2. Customers’ personal data is collected when they:

a) register an account in the Online Store, for the purpose of creating and managing an individual account. Legal basis: processing necessary for the performance of the contract for the Account service (Article 6(1)(b) GDPR);

b) place an order in the Online Store, for the purpose of performing the sales contract. Legal basis: processing necessary for the performance of the sales contract (Article 6(1)(b) GDPR);

c) subscribe to the Newsletter, for the purpose of performing a contract for an electronically supplied service. Legal basis: the data subject’s consent to the provision of the Newsletter service (Article 6(1)(a) GDPR).

3. When registering an account in the Online Store, the Customer provides:

a) an email address;

b) address details:

a. postal code and town or city;

b. country;

c. street and house/apartment number.

c) first and last name;

d) telephone number.

4. During registration, the Customer chooses their own password for the account. The Customer may change the password later in accordance with § 6.

5. When placing an order in the Online Store, the Customer provides:

a) an email address;

b) address details:

a. postal code and town or city;

b. country;

c. street and house/apartment number.

c) first and last name;

d) telephone number.

6. For business customers, the above information also includes:

a) the business name;

b) the NIP tax identification number.

7. To use the Newsletter service, the Customer provides only their email address.

8. When the Store Website is used, additional information may be collected, including the IP address assigned to the Customer’s computer or the internet provider’s external IP address, domain name, browser type, access time and operating system type.

9. Browsing data may also be collected, including information about the links Customers choose to follow and other actions they take in the Online Store. Legal basis: legitimate interests (Article 6(1)(f) GDPR) in making electronically supplied services easier to use and improving their functionality.

10. Certain personal data supplied by the Customer when using the Online Store may be processed to establish, pursue and enforce claims. This may include first and last name, information about the use of services where claims arise from that use, and other data necessary to demonstrate a claim, including the extent of any loss. Legal basis: legitimate interests (Article 6(1)(f) GDPR) in establishing, pursuing and enforcing claims and defending against claims before courts and other public authorities.

11. Providing personal data to HK Distribution Sp. z o.o. in connection with sales contracts or services offered through the Store Website is voluntary. However, failure to provide the data designated in the registration forms will prevent registration and the creation of a Customer Account. For orders placed without an account, failure to provide the necessary data will prevent the order from being placed and fulfilled.

§ 2 Who receives the data, and how long is it kept?

1. Customers’ personal data is passed to service providers used by HK Distribution Sp. z o.o. to operate the Online Store. Depending on the contractual arrangements and circumstances, these providers either follow the instructions of HK Distribution Sp. z o.o. regarding the purposes and means of processing (processors), or determine those purposes and means independently (controllers).

a) Processors. HK Distribution Sp. z o.o. uses providers that process personal data only on its instructions. These include hosting providers and providers of marketing systems, systems for analysing traffic in the Online Store and systems for analysing the effectiveness of marketing campaigns;

b) Controllers. HK Distribution Sp. z o.o. uses providers that do not act solely on its instructions and independently determine the purposes and means of using Customers’ personal data. These providers offer electronic payment and banking services.

2. Location. Service providers are based in Poland and other countries within the European Economic Area (EEA).

3. Customers’ personal data is retained:

a) Where processing is based on consent, HK Distribution Sp. z o.o. processes the data until consent is withdrawn, and afterwards for the period corresponding to the limitation period for claims that it may bring or that may be brought against it. Unless a specific provision states otherwise, the limitation period is six years, or three years for claims concerning periodic payments and claims related to business activity.

b) Where processing is based on performance of a contract, HK Distribution Sp. z o.o. processes the data for as long as necessary to perform that contract, and afterwards for the period corresponding to the limitation period for claims. Unless a specific provision states otherwise, the limitation period is six years, or three years for claims concerning periodic payments and claims related to business activity.

4. When a purchase is made in the Online Store, personal data may be passed to the following entities to deliver the ordered goods, depending on the Customer’s choice:

a) a courier company;

b) InPost Paczkomaty Sp. z o.o., based in Kraków, which provides delivery and parcel-locker services;

c) Poczta Polska S.A., based in Warsaw.

5. If the Customer chooses payment through przelewy24.pl, their personal data is passed, to the extent necessary to process the payment, to PayPro S.A., based at ul. Kanclerska 15, 60-327 Poznań, entered in the register of entrepreneurs maintained by the District Court Poznań – Nowe Miasto i Wilda in Poznań, 8th Commercial Division of the National Court Register, under KRS number 0000347935, NIP 7792369887, REGON 301345068.

6. Browsing data may be used to provide better customer service, analyse statistical data, tailor the Online Store to Customers’ preferences and administer the Online Store.

7. If a Customer subscribes to the Newsletter, HK Distribution Sp. z o.o. will send emails containing commercial information about promotions and new products available in the Online Store to that Customer’s email address.

8. Upon request, HK Distribution Sp. z o.o. discloses personal data to authorised public bodies, in particular the relevant units of the Public Prosecutor’s Office and the Police, the President of the Personal Data Protection Office, the President of the Office of Competition and Consumer Protection, or the President of the Office of Electronic Communications.

§ 3 Cookies and IP addresses

1. The Online Store uses small files called cookies. HK Distribution Sp. z o.o. stores them on a visitor’s device if the browser permits this. A cookie usually contains its originating domain name, an expiry time and a randomly generated identifier. Information collected through these files helps tailor the products offered by Hk Distribution Sp. z o.o. to visitors’ individual preferences and actual needs. It also enables the preparation of general statistics on visits to product pages in the Online Store.

2. HK Distribution Sp. z o.o. uses two types of cookies:

a) Session cookies: the stored information is deleted from the device’s memory when the browser session ends or the computer is switched off. Session cookies do not allow personal data or confidential information to be retrieved from Customers’ computers.

b) Persistent cookies: these remain in the Customer’s device memory until deleted or expired. Persistent cookies do not allow personal data or confidential information to be retrieved from the Customer’s computer.

3. HK Distribution Sp. z o.o. uses its own cookies for:

a) authenticating Customers in the Online Store and maintaining their session after login, so they do not need to re-enter their login and password on every page;

b) analysis, research and audience measurement, particularly the production of anonymous statistics that help explain how Customers use the Store Website and allow its structure and content to be improved.

4. HK Distribution Sp. z o.o. uses third-party cookies for:

a) collecting general, anonymous statistical data through Google Analytics (third-party cookie controller: Google Inc, based in the USA);

b) displaying the Rzetelny Regulamin Certificate through the rzetelnyregulamin.pl website (third-party cookie controller: Rzetelna Grupa sp. z o.o., based in Warsaw).

5. Cookies are safe for Customers’ computers. In particular, they do not allow viruses, unwanted software or malicious software to enter a Customer’s computer. Customers can nevertheless restrict or disable cookies in their browser. If they do so, they can still use the Online Store, except for functions that inherently require cookies.

6. Cookie settings can be changed in the following popular browsers:

a) Internet Explorer;

b) Microsoft Edge;

c) Mozilla Firefox;

d) Chrome and Chrome Mobile;

e) Safari and Safari Mobile;

f) Opera.

7. HK Distribution Sp. z o.o. may collect Customers’ IP addresses. An IP address is a number assigned by an internet service provider to a visitor’s computer and enables access to the internet. In most cases it is assigned dynamically and changes with each internet connection. HK Distribution Sp. z o.o. uses IP addresses to diagnose technical server problems, produce statistical analyses (for example, identifying the regions from which visits originate), administer and improve the Online Store, support security and, where necessary, identify unwanted automated browsing programs that place a load on the server.

8. The Online Store contains links to other websites. HK Distribution Sp. z o.o. is not responsible for the privacy practices of those websites.

§ 4 Rights of data subjects

1. Right to withdraw consent—legal basis: Article 7(3) GDPR.

a) The Customer may withdraw any consent given to HK Distribution Sp. z o.o.

b) Withdrawal of consent takes effect from the time it is withdrawn.

c) Withdrawal does not affect processing lawfully carried out by H Distribution Sp. z o.o. before consent was withdrawn.

d) Withdrawal has no negative consequences for the Customer, but may prevent continued use of services or functions that HK Distribution Sp. z o.o. may lawfully provide only with consent.

2. Right to object to processing—legal basis: Article 21 GDPR.

a) The Customer may object at any time, on grounds relating to their particular situation, to the processing of their personal data, including profiling, where HK Distribution Sp. z o.o. relies on legitimate interests. These may include marketing its products and services, compiling usage statistics for individual Online Store functions, making the Store easier to use and conducting satisfaction surveys.

b) An email opting out of marketing communications concerning products or services will be treated as an objection to the processing of the Customer’s personal data, including profiling, for those purposes.

c) If the Customer’s objection is justified and HK Distribution Sp. z o.o. has no other legal basis for processing, the data covered by that objection will be erased.

3. Right to erasure (“right to be forgotten”)—legal basis: Article 17 GDPR.

a) The Customer may request the erasure of all or some of their personal data.

b) The Customer may request erasure where:

a. the data is no longer needed for the purposes for which it was collected or processed;

b. they have withdrawn the consent on which processing was based;

c. they have objected to the use of their data for marketing;

d. the data is being processed unlawfully;

e. erasure is necessary to meet a legal obligation under EU law or the law of a Member State to which HK Distribution Sp. z o.o. is subject;

f. the data was collected in connection with the provision of information society services.

c) Despite a request to erase personal data following an objection or withdrawal of consent, HK Distribution Sp. z o.o. may retain certain personal data where processing is necessary to establish, pursue or defend claims, or to fulfil a legal obligation under EU law or the law of a Member State to which HK Distribution Sp. z o.o. is subject. This applies in particular to first and last name and email address retained to handle complaints and claims concerning the use of HK Diststribution Sp. z o.o. services, as well as residential/correspondence address and order number retained to handle complaints and claims concerning sales or service contracts.

4. Right to restriction of processing—legal basis: Article 18 GDPR.

a) The Customer may request restriction of the processing of their personal data. Until the request is considered, the Customer cannot use functions or services that require processing of the data covered by the request. HK Distribution Sp. z o.o. will also refrain from sending communications, including marketing communications.

b) The Customer may request restriction where:

a. where the Customer contests the accuracy of their personal data, HK Distribution Sp. z o.o. will restrict its use for the time needed to verify accuracy, but no longer than seven days;

b. processing is unlawful and the Customer requests restriction instead of erasure;

c. the data is no longer needed for the purposes for which it was collected or used, but the Customer needs it to establish, pursue or defend claims;

d. they have objected to the use of their data—in which case restriction applies for the time needed to assess whether, in the Customer’s particular situation, protecting their interests, rights and freedoms outweighs the controller’s interests in processing.

5. Right of access—legal basis: Article 15 GDPR.

a) The Customer may obtain confirmation from the controller as to whether their personal data is being processed and, if so, may:

a. access that data;

b. obtain information about the purposes of processing, the categories of personal data, recipients or categories of recipients, the intended retention period or the criteria used to determine it where a specific period cannot be given, their rights under the GDPR, their right to complain to a supervisory authority, the source of the data, automated decision-making including profiling, and safeguards for transfers outside the European Union;

c. obtain a copy of their personal data.

6. Right to rectification—legal basis: Article 16 GDPR.

a) The Customer may require the controller to correct inaccurate personal data without undue delay. Taking account of the purposes of processing, the Customer may request completion of incomplete data, including by supplying a supplementary statement, by emailing the address specified in § 7 of this Privacy Policy.

7. Right to data portability—legal basis: Article 20 GDPR.

a) The Customer may receive the personal data they supplied to the controller and transmit it to another controller of their choice. The Customer may also request direct transmission between controllers where technically feasible. In that case, the controller will provide the data in a CSV file, a commonly used, machine-readable format that allows it to be transferred to another controller.

8. Where the Customer exercises any of these rights, HK Distribution Sp. z o.o. will fulfil the request or refuse it without undue delay and no later than one month after receipt. If the complexity or number of requests prevents a response within one month, it will fulfil the request within a further two months, informing the Customer within the first month of the intended extension and the reasons for it.

9. The Customer may submit complaints, enquiries and requests to the controller concerning the processing of their personal data and the exercise of their rights.

10. The Customer may request a copy of the standard contractual clauses from HK Distribution Sp. z o.o. by contacting it as specified in § 7 of this Privacy Policy.

11. The Customer has the right to lodge a complaint with the President of the Polish Personal Data Protection Office concerning an infringement of their data protection rights or other rights under the GDPR.

§ 5 Services tailored to preferences and interests (profiling)

1. Profiling means any form of automated processing of Personal Data that uses Personal Data to evaluate certain personal aspects of an Individual, particularly to analyse or predict aspects relating to that Individual’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

2. Customers’ personal data may be processed automatically (profiling), but this will not produce legal effects concerning them or similarly significantly affect their situation.

3. Profiling by HK Distribution Sp. z o.o. involves processing Customers’ data automatically and manually, using it to evaluate certain information about a Customer, particularly to analyse or predict their personal preferences and interests.

4. To reach Customers with marketing messages through the Online Store Website, HK Distribution Sp. z o.o. uses its own cookies to obtain information about Customers’ activity on the Online Store Website. Details of the cookies used are set out in § 3. Legal basis: legitimate interests (Article 6(1)(f) GDPR) in tailoring marketing messages to preferences and interests.

§ 6 Security and passwords

1. HK Distribution Sp. z o.o. provides Customers with a secure, encrypted connection when personal data is transmitted and when they log in to their Customer Account on the Website. HK Distribution Sp. z o.o. uses an SSL certificate issued by one of the world’s leading companies in internet data security and encryption.

2. If a Customer with a Store account loses their password in any way, the Online Store allows a new password to be generated. HK Distribution Sp. z o.o. does not send password reminders. The password is stored in the database in encrypted form in a way that prevents it from being read. To generate a new password, the Customer must enter their email address in the form available through the “Forgot password” link beside the Online Store account login form. A new password will automatically be sent to the email address provided during registration or saved in the most recent account profile update.

3. HK Distribution Sp. z o.o. never sends correspondence, including emails, asking for login credentials, particularly the password for the Customer’s account.

§ 7 Changes to this Privacy Policy

1. This Privacy Policy may change. HK Distribution Sp. z o.o. will notify Customers 7 days in advance.

2. Please send questions about this Privacy Policy to info@adorome.pl.

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