Privacy Policy

This document sets out the terms and conditions for the processing of personal data (hereinafter also referred to as “data”) and cookies in the area of the sinesilk.com online store, run via the website, available at the URL: sinesilk.com, hereinafter referred to as the “Store”.

§1. General provisions

HOW TO CONTACT THE DATA CONTROLLER

The administrator of personal data processed within the Store is Agnieszka Saweczko-Rutkowska, conducting business activity under the name SINE AGNIESZKA SAWECZKO-RUTKOWSKA, with its registered office in Gdańsk (0-211) at ul. Dębinki 7a/2, registered in the Central Registration and Information on Business kept by the Minister of Development, under NIP 6040115066 and REGON 221224719.

The Data Controller can be contacted by phone: 507 155 161 and by e-mail: sinesilkscarf@gmail.com.

§2. Account registration in the store

ON WHAT BASIS DO WE PROCESS YOUR DATA?

When collecting personal data, we always inform about the legal basis for their processing. It results from the provisions of the 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, on the free movement of such data, and repealing Directive 95/46/EC – General Data Protection Regulation). When we inform you about:

  • Article 6(1)(a) of the GDPR – this means that we process personal data on the basis of the consent received,
  • Article 6(1)(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, at the request received,
  • Article 6(1)(c) of the GDPR – this means that we process personal data in order to comply with a legal obligation,
  • Article 6(1)(f) of the GDPR – this means that we process personal data in order to pursue legitimate interests.

§3. Basic functionalities of the store

INFORMATION ON DATA PROCESSING FOR THE PURPOSE OF CONCLUDING AND PERFORMING CONTRACTS, POSSIBLE PURSUIT OF CLAIMS AND DEFENSE AGAINST THEM

  1. We may process personal data necessary for the performance of the contract concluded with you. However, even before entering into the agreement, we may process personal data necessary to take action at your request. The processing of this data is based on Article 6(1)(b) of the GDPR.
  2. During the performance of the contract and after its performance, we process the personal data of the party in order to consider and pursue claims, if any. Our legitimate interest is, for example, the possibility of responding to a possible complaint, which we are obliged to do under separate provisions of civil law. In this case, we will process your personal data on the basis of our legitimate interest, which is to defend against or pursue possible claims. The processing of this data is based on Article 6(1)(f) of the GDPR.
  3. We will store this data for the period necessary to achieve the specified purposes, no later than until the statute of limitations for claims resulting from separate provisions of law expires.
  4. You have the right to access your data, rectify it, delete it, limit processing, the right to transfer data, as well as the right to lodge a complaint with the supervisory authority. In the case of data processing for the purpose specified in point 2, you also have the right to object to their processing.
  5. Providing this data is voluntary, however, failure to provide this data will prevent the conclusion of the contract or its implementation.
  6. The recipients of this data are: our hosting provider, e-mail service provider, IT service provider, transport service providers, accounting service provider, electronic payment service provider, banking service provider, legal, consulting and debt collection service provider and other service providers that we use for the specified purpose.

§4. Orders placed via the Store

INFORMATION ON DATA PROCESSING FOR THE PURPOSE OF SENDING THE NEWSLETTER

  1. We allow you to subscribe to the list of recipients of our newsletter. If you have used this functionality, we process your personal data for the purpose of sending it. The newsletter may contain advertising, commercial or marketing content.
  2. The processing of this data is based on Article 6(1)(f) of the GDPR.
  3. You have the right to unsubscribe from the newsletter at any time.
  4. We will store your data until you unsubscribe or until we stop sending you the newsletter.
  5. 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 its processing, as well as the right to lodge a complaint with the supervisory authority.
  6. Providing this data is voluntary, but failure to provide this data will prevent the newsletter from being sent.
  7. The recipients of this data are: our host, IT service provider, e-mail service provider and newsletter service provider.

§5. Sale

INFORMATION ON DATA PROCESSING FOR THE PURPOSE OF SENDING NOTIFICATIONS

  1. We allow 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 for the purpose of sending it. The notifications may contain advertising, commercial or marketing content.
  2. The processing of this data is based on your consent and thus on Article 6(1)(a) of the GDPR.
  3. You have the right to revoke your consent at any time. However, the withdrawal of consent does not affect the lawfulness of previous data processing.
  4. 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.
  5. You can revoke your consent to the processing of data in your web browser.
  6. You have the right to access your data, rectify it, delete it, limit processing, the right to transfer data, as well as the right to lodge a complaint with the supervisory authority.
  7. Providing this data is voluntary, but failure to provide this data will prevent notifications from being sent.
  8. The recipients of this data are: our host, advertiser and notification provider.

§ 6. Payments

INFORMATION ON DATA PROCESSING FOR DIRECT MARKETING PURPOSES

  1. We may process your personal data for direct marketing purposes. This happens, for example, when we respond to your message with details of our offer.
  2. The processing of this data is based on Article 6(1)(f) of the GDPR.
  3. We will store your data until necessary for the purpose of implementation.
  4. 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, as well as the right to lodge a complaint with the supervisory authority.
  5. Providing this data is voluntary, and failure to provide this data will prevent the implementation of direct marketing activities.
  6. The recipients of this data are: our hosting provider, IT service provider, e-mail service provider, advertising service provider

§7. INFORMATION ON DATA PROCESSING FOR SECURITY PURPOSES

  1. From the moment you start our website, in order to ensure the security of our services, we process data such as:
    • the public IP address of the requesting device,
    • Browser type and language
    • date and time of the query,
    • the number of bytes sent by the server,
    • the URL of the previously visited page, if the visit was made using this link,
    • information about errors that occurred during the execution of the inquiry.
  2. 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 ability to determine the IP address of a person performing an unauthorized activity in the Store, such as an attempt to break security, or publish prohibited content, or attempt unauthorized activities using our servers.
  3. The processing of this data is based on Article 6(1)(f) of the GDPR.
  4. We will store this data for the period necessary to achieve the specified purposes, no later than until the statute of limitations for claims resulting from separate provisions of law expires.
  5. You have the right to access your data, rectify it, delete it, limit its processing, object to its processing, as well as the right to lodge a complaint with the supervisory authority.
  6. Providing this data is a condition for using the Store. Failure to provide this data will prevent you from using the Store.
  7. The recipient of this data is our hosting provider and IT service provider.

§8. INFORMATION ON DATA PROCESSING FOR THE PURPOSE OF NOTIFICATION OF GOODS

  1. The Store has the functionality of sending a notification about the selected product to the e-mail address entered by the user.
  2. Our legitimate interest in this processing is to comply with the user’s request and subsequently to protect the Store against potential abuse.
  3. The processing of this data is based on Article 6(1)(f) of the GDPR.
  4. We will store this data for the period necessary to achieve the specified purposes, no later than until the statute of limitations for claims resulting from separate provisions of law expires.
  5. The data subject has the right to access their data, rectify it, delete it, limit its processing, object to its processing, as well as the right to lodge a complaint with the supervisory authority.
  6. Providing this data is a condition for sending the notification. Failure to provide this data will prevent this activity.
  7. The recipient of this data is our hosting provider and IT service provider.

§ 9. Out-of-court complaint consideration and redress

INFORMATION ABOUT DATA RECIPIENTS

We use external services to process personal data. Therefore, the recipients of your personal data may be third parties. When collecting personal data, we always inform about these recipients, but due to the primacy of legibility of the message, we do it briefly. Therefore, we hereby clarify that when we inform about individual categories of recipients, these are the following entities:

  • Delivery service provider/couriers: Furgonetka Sp. z o.o. Sp. k., Inżynierska 8, 03-422 Warsaw.
  • IT service provider: zenbox Sp. z o.o., 7 Dąbrowskiego Street, 42-200 Częstochowa.
  • Hosting provider: zenbox Sp. z o.o., 7 Dąbrowskiego Street, 42-200 Częstochowa.
  • E-mail service provider: zenbox Sp. z o.o., 7 Dąbrowskiego Street, 42-200 Częstochowa.
  • Provider of accounting services: Policzeni Tomasz Sikorski, Jaśkowa Dolina 11c/3, 80-252 Gdańsk.
  • Provider of legal / advisory / debt collection services – these service providers are appointed individually, in the event of each demand.
  • Provider of the newsletter service: The Rocket Science Group, LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 USA.
  • Banking service provider: mBank S.A., 18 Senatorska Street, 00-950 Warsaw.
  • Electronic payment service provider: PayPro S.A., Kanclerska 15, 60-327 Poznań.

§10. Withdrawal from the contract

INFORMATION ON DATA TRANSFERS TO THIRD COUNTRIES

  1. Due to the fact that we use the services of other providers, your personal data may be transferred outside the European Economic Area, namely to the country: United States of America (USA).
  2. The European Commission has determined that some countries outside the European Economic Area (EEA) adequately protect personal data.
  3. As the country to which we transfer personal data has not been recognised as a safe country, the transfer of data is based on a contract containing standard data protection clauses adopted by the European Commission.

§11. ABSOLUTE RIGHTS OF DATA SUBJECTS

When we write about the rights related to the processing of your personal data, we refer to the rights described below. The possibility of exercising the following rights is independent of the legal basis for the processing of personal data.

Right of access

You have the right to obtain confirmation from us as to whether or not we are processing personal data concerning you. If this is the case, you have the right to access this data, as well as to receive additional information about:

  • the purposes of the processing,
  • categories of relevant data,
  • recipients or categories of recipients to whom the data have been or will be disclosed, in particular recipients in third countries or international organisations,
  • where possible, the planned period of data storage, and if this is not possible, the criteria for determining this period,
  • the right to request us to rectify, delete or limit the processing of data, to object to such processing, as well as the right to lodge a complaint with the supervisory authority,
  • the source of the data, if your data was not collected from you,
  • automated decision-making, including profiling and the rules for making it, as well as the significance and expected consequences of such processing for you.

Upon receipt of such a request, we are required to provide you with a copy of the personal data undergoing processing. If such a request is received electronically and unless we receive any other objection, we will also provide information electronically.

Right to rectification

You have the right to request that we rectify inaccurate personal data concerning you without undue delay. Taking into account the purposes of the processing, you have the right to request the completion of incomplete personal data, including by providing an additional statement.

The right to delete data (to be forgotten)

You have the right to request that we delete personal data concerning you without undue delay. We are then obliged to delete your personal data without undue delay if one of the following circumstances applies:

  • you have withdrawn your consent to the processing of your personal data and we have no other basis for their processing,
  • you have successfully objected to the processing of data concerning you,
  • your personal data has been processed unlawfully,
  • Your personal data must be erased in order to comply with a legal obligation,
  • Your data has been collected in connection with the provision of information society services.

Right to restriction of processing

You have the right to request that we restrict processing in the following cases:

  • when you contest the accuracy of the data, for a period enabling us to verify its accuracy;
  • the processing is unlawful and you oppose the erasure of the data, requesting the restriction of their use instead,
  • we no longer need the personal data for the purposes of the processing, but you need them to establish, exercise or defend legal claims,
  • you have objected to the processing of your data – until it is determined whether the legitimate grounds on our part override the grounds for your objection.

Automated decisions, including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

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 Union 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 explicit consent.

Right to lodge a complaint

You have the right to lodge a complaint in connection with the processing of your personal data to the supervisory authority: President of the Office for Personal Data Protection, 2 Stawki Street, 00-193 Warsaw, tel. 22 531 03 00, fax. 22 531 03 01, e-mail: kancelaria@uodo.gov.pl.

§12. License Terms

RELATIVE RIGHTS OF DATA SUBJECTS

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 depends on the legal basis for the processing of personal data.

Right to withdraw consent to processing

Where we process your personal data on the basis of your consent, you have the right to withdraw your consent at any time. Naturally, the withdrawal of the consent granted 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, commonly used and 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:

  • on the basis of consent or on the basis of a contract, and
  • in an automated manner.

By exercising your right to data portability, you have the right to demand that we transmit your personal data directly to another controller, insofar as this is technically feasible. This right must not adversely affect the rights and freedoms of others.

Right to object

If we process your personal data on the basis of Article 6(1)(f) of the GDPR, you have the right to object to the processing of this data on grounds related to your particular situation.

We are then no longer permitted to process this personal data, unless we can prove the existence of:

  • compelling legitimate grounds for the processing, which must override your interests, rights and freedoms, or
  • grounds for establishing, pursuing or defending claims.

Also, if you object to the processing of your personal data for direct marketing purposes, we will not be able to process it for such purposes.

§13. INTRODUCTION TO COOKIES

The Store’s website uses cookies. These are commonly used, small files containing a string of characters, which 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 the next time you visit the website. Cookies can be categorized according to three classification methods.

In terms of the purposes of using cookies, we distinguish three categories of cookies:

  • Necessary files – these files enable the proper operation of the website and its functionalities, e.g. authentication or security cookies. Without saving them on your device, you will not be able to use the website.
  • Analytical files – these files allow you to monitor the websites you open, traffic sources, and the time you stay on the website. Without saving them, your use of the website’s functionality will not be limited.
  • Advertising cookies – these cookies allow you to display personalized ads on or off the website. Without saving them, your use of the website’s functionality will not be limited.

In terms of their validity period, we distinguish two categories of cookies:

  • session files – existing until the end of a given session,
  • persistent files – existing after the session is completed.

In terms of distinguishing the entity administering cookies, we distinguish:

  • our cookies,
  • Third-party cookies.

§14. Final Provisions

DATA CONTROLLER COOKIES

The cookies we administer allow us to:

  • access authentication,
  • maintaining the session after logging in,
  • securing the Store against hacker attacks,
  • “remembering” the content of the fields of the completed forms by the browser (optional),
  • “remembering” the items added to the cart by the browser.

Thanks to this, using the Store’s functionalities becomes easier and more pleasant.

§15. Definitions used in the regulations THIRD-PARTY COOKIES

The use of third-party cookies is subject to the privacy and cookie policies of those parties.

GOOGLE

We use cookies administered by Google Inc. 1600 Amphitheatre Pkwy, Mountain View, CA 94043, United States of America as part of the following services:

  • Google Ads – advertising files used to conduct and assess the quality of advertising campaigns carried out with the use of the Google Ads service,
  • Google Analytics – analytical files used to study user behavior and traffic and to compile traffic statistics,

The information collected by Google Inc is anonymous and aggregated. In particular, they do not contain features identifying (understood as personal data) of the Store’s users. By using the above-mentioned 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

The use of third-party cookies is subject to the privacy and cookie policies of those parties. The current policies of third parties in this regard can be found on the websites listed and here: https://www.e-regulaminy.pl/biuletyn/polityki-prywatnosci-i-plikow-cookies/.

§16. CONSENT TO THE USE AND MANAGEMENT OF COOKIES

With the exception of necessary cookies, their processing is based on the user’s consent.

Consent to the processing of cookies is voluntary and can be withdrawn at any time. However, it should be remembered that the lack of consent to the use of certain cookies may result in restrictions in the use of the Store and its functionalities, or even prevent its use.

Consent to the processing of cookies may be granted:

  • by means of the software settings installed on the telecommunications terminal equipment used by the user,
  • by using the button containing a statement of consent to the processing of cookies or confirming that you have read its terms and conditions,
  • using the settings available in the website area.

§17. CACHE

When you use the Store’s website, we may automatically use the cache installed on your device. As part of the local memory, it is possible to store data inter-session, i.e. between subsequent visits to the Store’s website. The purpose of using cache is to speed up the use of the Store by eliminating the situation in which the same data would be downloaded from the Store multiple times, thus overloading the user’s Internet connection. The cache can also store details such as a login password.

§18. LINKS TO OTHER WEBSITES OR SOFTWARE

The Store may contain links to other websites or software. We are not responsible for the rules of compliance with the privacy policy and the processing of cookies on these websites or in this software. We recommend that you read the privacy and cookie policies of these websites or software when you access them or before installing them.

§19. CHANGES TO THE PRIVACY AND COOKIES POLICY

  1. The Privacy and Cookies Policy comes into force on the date of publication on the Store’s website.
  2. The Privacy and Cookies Policy is amended by publishing its new content on the Store’s website.
  3. Information about the change to the Privacy and Cookies Policy is published in the area of the Store’s website, no later than 3 days before the date of entry into force of its new wording.