PRIVACY POLICY

TABLE OF CONTENTS:

1.            GENERAL PROVISIONS
2.            BASIS FOR DATA PROCESSING
3.            PURPOSE, BASIS AND PERIOD OF DATA PROCESSING IN THE ONLINE STORE
4.            DATA RECIPIENTS IN THE ONLINE STORE
5.            PROFILING IN THE ONLINE STORE
6.            RIGHTS OF THE DATA SUBJECT
7.            COOKIES IN THE ONLINE STORE AND ANALYTICS
8.            FINAL PROVISIONS

1.            GENERAL PROVISIONS

1.1. This privacy policy of the Online Shop is for informational purposes only, which means that it does not impose any obligations on Service Users or Customers of the Online Shop. The privacy policy primarily contains rules regarding the processing of personal data by the Administrator in the Online Shop, including the basis, purposes and period of personal data processing and the rights of data subjects, as well as information on the use of cookies and analytical tools in the Online Shop.

1.2. The controller of personal data collected via the Online Store is PIOTR MOCH, conducting business activity under the name PIOTR MOCH "HANDLES.PL", entered in the Central Register and Information on Economic Activity of the Republic of Poland kept by the minister responsible for the economy, with the address of the place of business and correspondence address: ul. Zgoda 12, 60-128 Poznań, NIP (Tax Identification Number): 7792012346, REGON: 300664475 and e-mail address: biuro@handles.pl- hereinafter referred to as the "Administrator" and also being the Online Store Service Provider and Seller.

1.3. Personal data in the Online Store is processed by the Administrator in accordance with applicable law, in particular in accordance with Regulation (EU) 2016/679 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 "GDPR" or "GDPR Regulation". Official text of the GDPR: http://eur-lex.europa.eu/legal-content/PL/TXT/?uri=CELEX%3A32016R0679

1.4. The use of the Online Store, including making purchases, is voluntary. Similarly, the provision of personal data by the Service Recipient or Customer using the Online Store is voluntary, with two exceptions: (1) concluding contracts with the Administrator - failure to provide, in the cases and to the extent indicated on the Online Store website and in the Online Store Regulations and this privacy policy, the personal data necessary to conclude and perform a Sales Contract or a contract for the provision of Electronic Services with the Administrator results in the inability to conclude such a contract. In such a case, the provision of personal data is a contractual requirement and if the data subject wishes to conclude a given agreement with the Administrator, they are obliged to provide the required data. Each time, the scope of data required to conclude an agreement is indicated in advance on the Online Store website and in the Online Store Regulations; (2) the Administrator's statutory obligations - the provision of personal data is a statutory requirement resulting from generally applicable laws imposing on the Administrator the obligation to process personal data (e.g. processing data for the purpose of keeping tax or accounting records) and failure to provide such data will prevent the Administrator from performing these obligations.

1.5.      The Controller takes special care to protect the interests of the persons whose personal data it processes, and in particular is responsible for and ensures that the data it collects is: (1) processed lawfully; (2) collected for specified, lawful purposes and not further processed in a manner incompatible with those purposes; (3) factually correct and adequate in relation to the purposes for which they are processed; (4) stored in a form which permits identification of data subjects for no longer than is necessary for the purposes of processing; and (5) processed in a manner that ensures appropriate security of personal data,  including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

1.6. Taking into account the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, the Controller shall implement appropriate technical and organisational measures to ensure that processing is performed in accordance with this Regulation and to be able to demonstrate this. These measures shall be reviewed and updated as necessary. The Controller shall use technical measures to prevent unauthorised persons from obtaining and modifying personal data transmitted electronically.

1.7. All words, expressions and acronyms appearing in this privacy policy and beginning with a capital letter (e.g. Seller, Online Store, Electronic Service) shall be understood in accordance with their definition contained in the Terms and Conditions of the Online Store available on the Online Store's website.

2.            BASIS FOR DATA PROCESSING

2.1. The Controller is authorised to process personal data in cases where – and to the extent that – at least one of the following conditions is met: (1) the data subject has consented to the processing of their personal data for one or more specific purposes; (2) 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) processing is necessary for compliance with a legal obligation to which the Controller is subject; 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 at least one of the grounds specified in section 2.1 of the privacy policy to be present in each case. The specific grounds for the processing of personal data of Service Users and Customers of the Online Store by the Controller are indicated in the next section of the privacy policy – in relation to the specific purpose of the processing of personal data by the Controller.

3.            PURPOSE, BASIS AND PERIOD OF DATA PROCESSING IN THE ONLINE SHOP.

3.1. In each case, the purpose, basis and period of processing of personal data by the Controller, as well as the recipients of such data, result from the actions taken by a given Service Recipient or Customer in the Online Store or by the Controller. For example, if a Customer decides to make purchases in the Online Store and chooses to collect the purchased Product in person instead of having it delivered by courier, their personal data will be processed for the purpose of performing the concluded Sales Agreement, but will no longer be made available to the carrier delivering the parcels on behalf of the Controller. 

3.2. The Controller 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 Period of data processing

Performance of the Sales Agreement or the agreement for the provision of Electronic Services or taking action at the request of the data subject prior to the conclusion of the above-mentioned agreements Article 6(1)(b) of the GDPR (performance of a contract) - 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

                The data is stored for the period necessary for the performance, termination or other expiry of the concluded Sales Agreement or agreement for the provision of Electronic Services.

Sending commercial information, including direct marketing, using telecommunications terminal equipment (e.g. e-mail, telephone) or automatic calling systems Article 6(1)(f) of the GDPR (legitimate interest of the controller) – processing is necessary for the purposes of the legitimate interests pursued by the Controller, which include direct marketing  – consisting in caring for the interests and good image of the Controller, its Online Store and striving to sell Products – for example, in connection with the prior consent of the data subject (e.g. when subscribing to the Newsletter) to send commercial information using telecommunications terminal equipment, such as e-mail or telephone, depending on the scope of the consent given. The data is stored for the duration of the legitimate interest pursued by the Administrator, but no longer than for the period of limitation of the Administrator's claims against the data subject in relation to the Administrator's business activity. The limitation period is specified by law, in particular the Civil Code (the basic limitation period for claims related to business activities is three years, and for Sales Agreements two years).

The Controller may not process data for direct marketing purposes if the data subject has effectively objected to this.

Additionally, if the basis for processing is consent, the data is stored until the data subject withdraws their consent to further processing of their data for the purpose specified in the consent, but without affecting the lawfulness of the processing that was carried out on the basis of consent before its withdrawal.

Keeping tax records Article 6(1)(c) of the GDPR in conjunction with Article 86(1) of the Tax Ordinance of 17 January 2017 (Journal of Laws of 2017, item 201) - processing is necessary for compliance with a legal obligation to which the Controller is subject;

                The data is stored for the period required by law, which requires the Controller to store tax records (until the expiry of the limitation period for tax liabilities, unless tax laws provide otherwise).

Establishing, pursuing or defending claims that may be raised by the Controller or that may be raised against the Controller Article 6(1)(f) of the GDPR (legitimate interests of the controller) - processing is necessary for the purposes of the legitimate interests pursued by the Controller  – consisting in the establishment, investigation or defence of claims that may be raised by the Controller or that may be raised against the Controller

                The data is stored for the duration of the legitimate interest pursued by the Controller, but no longer than the limitation period for claims that may be raised against the Controller (the basic limitation period for claims against the Controller is six years).

Use of the Online Store website and ensuring its proper functioning Article 6(1)(f) of the GDPR (legitimate interest of the Controller) – processing is necessary for the purposes of the legitimate interests pursued by the Controller – consisting in the operation and maintenance of the Online Store website. The data is stored for the duration of the legitimate interest pursued by the Controller, but no longer than for the limitation period for the Controller's claims against the data subject in relation to the Controller's business activity. The limitation period is specified by law, in particular the Civil Code (the basic limitation period for claims related to business activities is three years, and for sales contracts two years).

Keeping statistics and analysing traffic in the Online Store Article 6(1)(f) of the GDPR (legitimate interest of the controller) – processing is necessary for the purposes of the legitimate interests pursued by the Controller – consisting in keeping statistics and analysing traffic in the Online Store in order to improve the functioning of the Online Store and increase sales of Products. The data is stored for the duration of the legitimate interest pursued by the Controller, but no longer than the limitation period for the Administrator's claims against the data subject in relation to the Administrator's business activity. The limitation period is specified by law, in particular the Civil Code (the basic limitation period for claims related to business activity is three years, and for sales contracts two years).

4.            DATA RECIPIENTS IN THE ONLINE STORE

4.1. For the proper functioning of the Online Store, including the performance of Sales Agreements, it is necessary for the Administrator to use the services of external entities (such as a software provider, courier or payment processor). The Administrator uses only the services of such processors who provide sufficient guarantees to implement appropriate technical and organisational measures so that the processing meets the requirements of the GDPR and protects the rights of data subjects.

4.2. Personal data may be transferred by the Controller to a third country, provided that the Controller ensures that in such a case this will be done in relation to a country that provides an adequate level of protection in accordance with the GDPR, and the data subject has the possibility to obtain a copy of their data. The Controller transfers the collected personal data only in the case and to the extent necessary to achieve the purpose of data processing in accordance with this privacy policy.

4.3. The personal data of Service Users and Customers of the Online Store may be transferred to the following recipients or categories of recipients:

4.3.1. carriers/forwarders/ courier brokers - in the case of a Customer who uses the Online Store to have a Product delivered by post or courier, the Administrator shall make the collected personal data of the Customer available to the selected carrier, forwarder or intermediary performing the delivery on behalf of the Administrator to the extent necessary to deliver the Product to the Customer.

4.3.2. entities handling electronic or card payments - in the case of a Customer who uses electronic or card payment methods in the Online Store, the Administrator shall make the collected personal data of the Customer available to the selected entity handling the above payments in the Online Store on behalf of the Administrator to the extent necessary to handle the payment made by the Customer.

4.3.3. credit providers/lessors – in the case of a Customer who uses the instalment payment method or lease payment method in the Online Store, the Administrator shall make the collected personal data of the Customer available to the selected credit provider or lessor handling the above payments in the Online Store at the request of the Administrator to the extent necessary to process the payment made by the Customer.

4.3.4. service providers supplying the Administrator with technical, IT and organisational solutions enabling the Administrator to conduct business activity, including the Online Store and the Electronic Services provided through it (in particular, suppliers of computer software for running the Online Store, e-mail and hosting providers, and suppliers of software for company management and technical support to the Administrator) - The Administrator shall make the collected personal data of the Customer available to a selected supplier acting on its behalf only in the case and to the extent necessary to achieve a given purpose of data processing in accordance with this privacy policy.

4.3.5. accounting, legal and advisory service providers providing the Administrator with accounting, legal or advisory support (in particular, an accounting office, law firm or debt collection company) – the Controller shall make the collected personal data of the Customer available to a selected supplier acting on its behalf only in the case and to the extent necessary to achieve a given data processing purpose in accordance with this privacy policy.

4.3.6. providers of social plugins, scripts and other similar tools enabling the browser of a person visiting the Online Store website to download content from the providers of the aforementioned plug-ins (e.g. logging in using social media login details) and to transfer the visitor's personal data to these providers for this purpose, including:

4.3.6.1.             Meta Platforms Ireland Ltd. – The Administrator uses Facebook social plugins on the Online Store website (e.g. the Like button, Share button or logging in using Facebook login details) and therefore collects and shares the personal data of the Service User using the Online Store website with Meta Platforms Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland) to the extent and in accordance with the privacy policy available here: https://www.facebook.com/about/privacy/ (this data includes information about activities on the Online Store website – including information about the device, websites visited, purchases, advertisements displayed and how the services are used – regardless of whether the Service User has a Facebook account and is logged in to Facebook).

4.3.6.2. Twitter Inc. – The Administrator may use Twitter social plugins (e.g. the "Tweet" button) on the Online Store website and, in connection with this, collects and shares the personal data of the Service User using the Online Store website with Twitter Inc. (1355 Market Street, San Francisco, California) to the extent and in accordance with the privacy policy available here: https://twitter.com/en/privacy (this data includes information about activities on the Online Store website – including information about the device, websites visited, purchases, advertisements displayed and how the services are used – regardless of whether the Service Recipient has a Twitter account and is logged in to Twitter).

4.3.6.3. Pinterest Inc. – The Administrator uses Pinterest social plugins (e.g. Save) on the Online Store website and, in connection with this, collects and shares the personal data of the Service User using the Online Store website with Pinterest Inc. (505 Brannan St. San Francisco, California 94107) to the extent and in accordance with the privacy policy available here: https://policy.pinterest.com/pl/privacy-policy.

5.            PROFILING IN THE ONLINE STORE

5.1. The GDPR imposes on the Controller the obligation to inform about automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR, and – at least in these cases – relevant information about the rules for making such decisions, as well as the significance and anticipated 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 Controller may use profiling in the Online Store for direct marketing purposes, but the decisions made by the Controller on this basis do not concern the conclusion or refusal to conclude a Sales Agreement or the possibility of using Electronic Services in the Online Store. The effect of using profiling in the Online Store may be, for example, granting a discount to a given person, sending them a discount code, reminding them about unfinished purchases, sending a proposal for a Product that may correspond to the interests or preferences of a given person, or offering better conditions compared to the standard offer of the Online Store. Despite profiling, the person is free to decide whether they want to take advantage of the discount or better terms and conditions received in this way and make a purchase in the Online Store.

5.3. Profiling in the Online Store consists in the automatic analysis or prediction of a person's behaviour on the Online Store website, e.g. by adding a specific Product to the basket, viewing the page of a specific Product in the Online Store, or by analysing the history of previous purchases made in the Online Store. The condition for such profiling is that the Controller has the personal data of a given person in order to be able to send them, for example, a discount code.

5.4. The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them.

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 their personal data, rectification, erasure ("right to be forgotten") or restriction of processing, and has the right to object to the processing, as well as the right to transfer their data. The detailed conditions for exercising the above rights are set out in Articles 15-21 of the GDPR.

6.2. Right to withdraw consent at any time – a person whose data is processed by the Controller on the basis of consent (pursuant to Article 6(1)(a) or Article 9(2)(a) of the GDPR), has the right to withdraw consent at any time without affecting the lawfulness of the processing carried out on the basis of consent before its withdrawal.

6.3.      Right to lodge a complaint with a supervisory authority – a person whose data is processed by the Controller has the right to lodge a complaint with a supervisory authority in the manner and procedure specified in the provisions of the GDPR and Polish law, in particular the Personal Data Protection Act. The supervisory authority in Poland is the President of the Personal Data Protection Office.

6.4. Right to object – the data subject has the right to object at any time, on grounds relating to their particular situation, to the processing of their personal data based on Article 6(1)(e) (public interest or public tasks) or (f) (legitimate interests of the controller), including profiling based on these provisions. In such a case, the controller may no longer process such personal data unless he demonstrates 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 legal claims.

6.5. Right to object to direct marketing - if personal data is processed for direct marketing purposes, the data subject has the right to object at any time to the processing of their personal data for such marketing purposes, 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, you may contact the Controller by sending a relevant message in writing or by e-mail to the Controller's address indicated at the beginning of the privacy policy or by using the contact form available on the Online Shop website.

7.            COOKIES IN THE ONLINE STORE AND ANALYTICS

7.1.      Cookies are small pieces of information in the form of text files, sent by the server and stored on the side of the person visiting the Online Store website (e.g. on the hard drive of a computer, laptop or smartphone memory card, depending on the device used by the visitor to our Online Store). Detailed information about cookies and their history can be found, among others, here: https://pl.wikipedia.org/wiki/HTTP_cookie.

7.2. Cookies that may be sent by the Online Shop website can be divided into different types according to the following criteria:

By provider:

1) own (created by the Administrator's Online Store website) and

2) belonging to third parties (other than the Administrator) Due to their storage period on the device of the person visiting the Online Shop website:

1) session cookies (stored until the user logs out of the Online Shop or closes their web browser) and

2) persistent (stored for a specified period of time, defined by the parameters of each file, or until manually deleted) Depending on their purpose:

1) necessary (enabling the proper functioning of the Online Shop website),

2) functional/preference cookies (enabling the Online Store website to be adapted to the preferences of the person visiting the website),

3) analytical and performance cookies (collecting information about how the Online Store website is used),

4) marketing, advertising and social media (collecting information about the visitor to the Online Store website in order to display advertisements to that person, personalise them, measure their effectiveness and conduct other marketing activities, including on websites separate from the Online Store website, such as social media portals or other websites belonging to the same advertising networks as the Online Store)

7.3. The Administrator may process the data contained in Cookies when visitors use the Online Shop website for the following specific purposes:

Purposes of using cookies in the Administrator's Online Store to identify Service Users as logged in to the Online Store and to show that they are logged in (necessary cookies)

                remembering Products added to the basket in order to place an Order (necessary cookies)

                remembering data from completed Order Forms, surveys or login details to the Online Store (necessary and/or functional/preference cookies)

                customising the content of the Online Shop website to the individual preferences of the Service Recipient (e.g. regarding colours, font size, page layout) and optimising the use of the Online Shop website (functional/preference cookies)

                keeping anonymous statistics showing how the Online Store website is used (analytical and performance cookies)

                displaying and rendering advertisements, limiting the number of ad views and ignoring advertisements that the Service User does not want to see, measuring the effectiveness of advertisements, as well as personalising advertisements, i.e. studying the behaviour of visitors to the Online Store through anonymous analysis of their activities (e.g. repeated visits to specific pages, keywords, etc.) in order to create their profile and provide them with advertisements tailored to their anticipated interests, including when they visit other websites in the advertising network of Google Ireland Ltd. and Facebook, i.e. Meta Platforms Ireland Ltd. (marketing, advertising and social media cookies)

7.4. You can check which cookies (including the duration of cookies and their provider) are currently being sent by the Online Shop website in the most popular web browsers as follows:

In Chrome:

(1) click on the padlock icon on the left side of the address bar, (2) go to the "Cookies" tab. In Firefox:

(1) in the address bar, click on the shield icon on the left, (2) go to the "Allowed" or "Blocked" tab, (3) click on the "Cross-site tracking cookies", "Social media tracking elements" or "Content with tracking elements" field. In Internet Explorer:

(1) click on the "Tools" menu, (2) go to the "Internet Options" tab, (3) go to the "General" tab, (4) go to the "Settings" tab, (5) click on the "View files" box

In Opera:

(1) in the address bar, click on the padlock icon on the left, (2) go to the "Cookies" tab. In Safari:

(1) click on the "Preferences" menu, (2) go to the "Privacy" tab, (3) click on the "Manage website data" field. Regardless of the browser, using the tools available, for example, on the website: https://www.cookiemetrix.com/ or: https://www.cookie-checker.com/

7.5. By default, most web browsers available on the market accept cookies by default. Everyone has the option to specify the conditions for using cookies using their own web browser settings. This means that you can, for example, partially restrict (e.g. temporarily) or completely disable the storage of cookies – in the latter case, however, this may affect some of the functionalities of the Online Shop (for example, it may not be possible to complete the Order process via the Order Form because the Products in the basket are not remembered during the subsequent steps of placing the Order).

7.6. Your web browser settings regarding cookies are important in terms of consenting to the use of cookies by our Online Store – in accordance with the regulations, such consent may also be expressed through your web browser settings. Detailed information on changing cookie settings and deleting cookies in the most popular web browsers is available in the help section of your web browser and on the following pages (just click on the link):

in Chrome

in Firefox

in Opera

in Safari

in Microsoft Edge

7.7. The Administrator may use Google Analytics and Universal Analytics services provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) in the Online Store. These services help the Administrator to compile statistics and analyse traffic in the Online Shop. The collected data is processed as part of the above services to generate statistics helpful in administering the Online Shop and analysing traffic in the Online Shop. This data is aggregated. Using the above services in the Online Store, the Administrator collects data such as the sources and medium of acquisition of visitors to the Online Store and their behaviour on the Online Store website, information about the devices and browsers they use to visit the website, IP and domain, geographical data and demographic data (age, gender) and interests.

7.8. It is possible for a person to easily block the sharing of information about their activity on the Online Store website with Google Analytics – for this purpose, for example, you can install a browser add-on provided by Google Ireland Ltd. available here: https://tools.google.com/dlpage/gaoptout?hl=pl.

7.9. In connection with the Administrator's use of advertising and analytical services provided by Google Ireland Ltd. in the Online Store, the Administrator indicates that full information on the rules for processing data of visitors to the Online Store (including information stored in cookies) by Google Ireland Ltd. can be found in the privacy policy of Google services available at: https://policies.google.com/technologies/partner-sites.

8.            FINAL PROVISIONS

8.1. The Online Store may contain links to other websites. The Administrator urges you to read the privacy policy set out on those websites after you have moved to them. This privacy policy applies only to the Administrator's Online Store.