PRIVACY POLICY

PRIVACY POLICY INNPRO ONLINE SHOP

TABLE OF CONTENTS:

1. GENERAL PROVISIONS
2. THE BASIS OF DATA PROCESSING
3. 3. PURPOSE, BASIS AND DURATION OF DATA PROCESSING IN THE ONLINE SHOP
4. 4. RECIPIENTS OF DATA IN THE ONLINE SHOP
5. PROFILING IN THE ONLINE SHOP 6. DATA SUBJECT'S RIGHTS
7. COOKIES IN THE WEBSHOP AND ANALYTICS 8. FINAL PROVISIONS

1. GENERAL PROVISIONS


1.1 This Internet Shop's privacy policy is informative, which means that it is not a source of obligation for the Service Recipients or the Customers of the Internet Shop. The Privacy Policy contains mainly the rules regarding personal data processing by the Administrator in the Internet Shop, including the basis, purposes and duration of personal data processing and the rights of data subjects, as well as information on the use of Cookies and analytical tools in the Internet Shop.

1.2 The Administrator of personal data collected via the Internet Shop is Robert Błędowski conducting business activity under the name INNPRO ROBERT BŁĘDOWSKI, registered in the Central Register of Business Activity and Information of the Republic of Poland, conducted by the minister competent for economy, having: business address and address for delivery: ul. Rudzka 65c, 44-200 Rybnik, NIP 6423040197, REGON 243139422, electronic mail address: kontakt@innpro.pl, telephone number: 533 234 303 - hereinafter referred to as the "Administrator" and being at the same time the Internet Shop Service Provider and the Seller.

1.3 Personal data in the Online Shop are processed by the Administrator in accordance with applicable laws, in particular in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals 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 "RODO" or "RODO Regulation". The official text of the RODO Regulation: http://eur-lex.europa.eu/legalcontent/PL/TXT/?uri=CELEX%3A32016R0679

1.4 The use of the Online Shop, including making purchases, is voluntary. Similarly, the related provision of personal data by the Service Recipent or Client using the Online Shop is voluntary, subject to two exceptions: (1) conclusion of agreements with the Administrator - failure to provide personal data necessary for the conclusion and performance of a Sales Agreement or an agreement for the provision of an Electronic Service with the Administrator in the cases and to the extent indicated on the website of the Internet Shop and in the Terms and Conditions of the Internet Shop and this Privacy Policy results in the impossibility to conclude that agreement. Providing personal data in such a case is a contractual requirement and if the data subject wants to conclude a given agreement with the Administrator, he or she is obliged to provide the required data. Each time the scope of data required to conclude a contract is indicated previously on the website of the Internet Shop and in the Terms and Conditions of the Internet Shop; (2) statutory obligations of the Administrator - providing personal data is a statutory requirement resulting from universally applicable laws imposing an obligation to process personal data on the Administrator (e.g. processing of data for the purposes of keeping tax or accounting books), and failing to provide such data will prevent the Administrator from fulfilling those obligations.

1.5 The Controller shall exercise particular care to protect the interests of persons to whom the personal data processed by him/her relate, and in particular shall be responsible for and ensure that the data collected by him/her are: (1) processed lawfully; (2) collected for specified, legitimate purposes and not subject to further processing incompatible with those purposes; (3) substantively correct and adequate in relation to the purposes for which they are processed; (4) kept in a form which permits identification of data subjects for no longer than is necessary to achieve the purpose of processing; and (5) processed in a manner which ensures adequate security of personal data, including protection against unauthorised or unlawful processing and accidental loss, destruction or damage, by means of appropriate technical or organisational measures.

1.6 Having regard to the nature, scope, context and purposes of the processing and the risk of violation of the rights or freedoms of natural persons of varying probability and seriousness, the Controller shall implement appropriate technical and organisational measures to ensure that the processing is carried out in accordance with this Regulation and to be able to demonstrate it. These measures shall be reviewed and updated as necessary. The Controller shall apply technical measures to prevent unauthorised persons from acquiring and modifying personal data transmitted electronically.

1.7 All words, phrases and acronyms appearing in this Privacy Policy and starting with a capital letter (e.g. Seller, Internet Shop, Electronic Service) shall be understood in accordance with their definition contained in the Rules of the Internet Shop available at the websites of the Internet Shop. 2. GROUNDS FOR DATA PROCESSING


2.1 The Controller shall be entitled to process personal data where, and to the extent that, one or more of the following conditions are met: (1) the data subject has given his or her consent to the processing of his or her personal data for one or more specified 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 incumbent on the Controller or (4) processing is necessary for the purposes of 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 shall in each case require the existence of at least one of the grounds indicated in Point. 2.1 of the Privacy Policy. Specific grounds for processing of personal data of the Internet Shop's Customers and clients by the Administrator are indicated in the next point of the privacy policy - with reference to a given purpose of personal data processing by the Administrator.

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


3.1 In each case, the purpose, basis and period and recipients of personal data processed by the Administrator result from the actions taken by a given Service Recipient or Client in the Internet Shop or by the Administrator. For example, if the Customer decides to make purchases in the Internet Shop and chooses personal collection of the purchased Product instead of courier delivery, his or her personal data will be processed in order to perform the Sales Agreement concluded, but will no longer be made available to the carrier performing the shipment on behalf of the Administrator.

3.2 The Administrator can process personal data within the Internet Shop for the following purposes, on the basis and for the periods indicated in the table below:

Purpose of data processing

Legal basis of data processing

Data storage period

Performance of a Sales Agreement or an agreement for the provision of Electronic Services or taking action at the request of the data subject prior to entering into the aforementioned agreements

Article 6(1)(b) of the RODO Regulation (performance of a contract) - processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject prior to entering into a contract.

The data shall be stored for the period necessary for the execution, termination or other expiration of the concluded Sales Agreement or Electronic Service Agreement.

Direct marketing

Article 6(1)(f) of the RODO Regulation (legitimate interest of the controller) - processing is necessary for the purposes deriving from the Administrator's legitimate interests - consisting in promoting the interests and the good image of the Administrator, its Internet Shop and striving to sell the Products

The data shall be stored for the period of existence of the legally justified interest pursued by the Administrator, however, not longer than for the period within which the Administrator's claims against the data subject by virtue of the Administrator's economic activity are time-barred. The period of limitation shall be determined by law, in particular the Civil Code (the basic limitation period for claims related to business activities is three years, and for a Sales Agreement two years).

The Administrator may not process data for the purposes of direct marketing in the case of an effective objection to this effect expressed by the data subject.

Marketing

Article 6(1)(a) of the RODO Regulation (consent) - the data subject has given consent for his/her personal data to be processed for marketing purposes by the Administrator.

Data shall be stored until the data subject withdraws his/her consent to the further processing of his/her data for this purpose.

Bookkeeping

Article 6(1)(c) of the RODO Regulation in conjunction with Article 74(2) of the Accounting Act, i.e. of 30 January 2018. (Journal of Laws of 2018, item 395) - processing is necessary for the fulfilment of a legal obligation incumbent on the Administrator


The data are kept for the period required by legal regulations requiring the Administrator to keep accounting books (5 years, counting from the beginning of the year following the financial year to which the data refer).

Establishing, asserting or defending claims which may be raised by the Administrator or which may be raised against the Administrator

Article 6(1)(f) of the RODO Regulation (legitimate interest of the controller) - processing is necessary for the purposes resulting from the Administrator's legitimate interests - consisting in determining, asserting or defending claims which may be raised by the Administrator or which may be raised against the Administrator.

The data is stored for the period of existence of the legally justified interest pursued by the Administrator, however no longer than for the period of limitation of claims that may be raised against the Administrator (the basic limitation period for claims against the Administrator is six years).

Using the Internet Shop website and ensuring its proper operation

Article 6(1)(f) of the RODO Regulation (legitimate interest of the Administrator) - processing is necessary for the purposes deriving from the Administrator's legitimate interests - consisting in running and maintaining the Internet Shop's website

The data shall be stored for the period of existence of the legally justified interest pursued by the Administrator, however not longer than the period within which the Administrator's claims against the data subject by virtue of the Administrator's economic activity are time-barred. The period of limitation shall be determined by law, in particular the Civil Code (the basic limitation period for claims related to business activities is three years, and for a Sales Agreement two years).

Keeping statistics and analysing traffic in the Internet Shop

Article 6(1)(f) of the RODO Regulation (legitimate interest of the controller) - processing is necessary for the purposes resulting from the Administrator's legitimate interests - consisting in conducting statistics and traffic analysis in the Internet Shop in order to improve the functioning of the Internet Shop and increase sales of Products

The data shall be stored for the period of existence of the legally justified interest pursued by the Administrator, however, no longer than for the period of expiration of the Administrator's claims against the data subject on account of the Administrator's economic activity. The period of limitation shall be determined by law, in particular the Civil Code (the basic limitation period for claims related to business activities is three years, and for a Sales Agreement - two years).

4. RECIPIENTS OF DATA IN THE INTERNET SHOP


4.1 For the proper functioning of the Internet Shop, including the performance of Sales Agreements concluded, it is necessary for the Administrator to use the services of external entities (such as e.g. software provider, courier or payment processor). The Administrator shall only use the services of such processors who provide sufficient guarantees to implement appropriate technical and organisational measures so that the processing complies with the requirements of the RODO Regulation and protects the rights of data subjects.

4.2 The transfer of data by the Controller does not take place in every case and not to all recipients or categories of recipients indicated in the Privacy Policy - the Controller transfers data only if it is necessary to achieve a given purpose of personal data processing and only to the extent necessary to achieve it. For example, if the Customer uses personal collection, his/her data will not be transferred to the carrier cooperating with the Administrator.

4.3 Personal data of Service Recipients and Customers of the Internet Shop may be transferred to the following recipients or categories of recipients:

1.1.1. carriers / forwarders / courier brokers / entities operating the warehouse and/or the dispatch process - in the case of a Customer who uses the method of Product delivery in the Internet Shop by mail or by courier, the Administrator makes the collected personal data of the Customer available to the selected carrier, forwarder or intermediary performing the shipment on behalf of the Administrator, and if the shipment is made from an external warehouse - to the entity operating the warehouse and/or the dispatch process - to the extent necessary to complete the delivery of the Product to the Customer.

1.1.2. entities processing electronic or credit card payments - if a Customer uses the electronic or credit card payment method in the Internet Shop, the Administrator shall make available collected personal data of the Customer to a selected entity processing the aforementioned payments in the Internet Shop on the basis of the Administrator's order, to the extent necessary to handle the payment made by the Customer.

1.1.3. crediting entities / lessors - in case of a Customer who uses the instalment or leasing payment method in the Internet Shop, the Administrator shall make available the collected personal data of the Customer to a selected creditor or lessor handling the aforementioned payments in the Internet Shop on the order of the Administrator to the extent necessary to handle the payment executed by the Customer.

1.1.4. service providers supplying the Administrator with technical, IT and organisational solutions, which enable the Administrator to run its business, including the Internet Shop and the Electronic Services provided by means of it (in particular, suppliers of computer software for running the Internet Shop, e-mail and hosting providers, as well as suppliers of business management and technical support software for the Administrator) - the Administrator shall make the collected personal data of the Customer available to a chosen supplier acting on its behalf only in the case and to the extent necessary to carry out a given purpose of data processing in accordance with this Privacy Policy.

1.1.5. accounting, legal and advisory service providers providing the Administrator with accounting, legal or advisory support (in particular an accounting office, a law firm or a debt collection agency) - the Administrator shall make the collected personal data of the Client available to the chosen provider acting on its behalf only if and to the extent necessary for the accomplishment of a given purpose of data processing in accordance with this Privacy Policy.

5. PROFILING IN THE ONLINE SHOP


5.1 The RODO Regulation imposes an obligation on the Controller to provide information on automated decision-making, including profiling, as referred to in Article 22(1) and (4) of the RODO Regulation, and, at least in these cases, relevant information on the modalities of such decisionmaking, as well as on the significance and the envisaged 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 Internet Shop for direct marketing purposes, but the decisions taken on its basis by the Controller do not concern conclusion or refusal of the Sales Agreement or the possibility of using Electronic Services in the Internet Shop. The effect of using profiling in the Internet Shop may be e.g. granting a given person a discount, sending him/her a discount code, reminding about unfinished shopping, sending a proposal of a Product which may correspond to interests or preferences of a given person or offering better conditions in comparison with the standard offer of the Internet Shop. Despite the profiling, it is up to the individual to freely decide whether they want to take advantage of the discount or better conditions received in this way and make a purchase from the Online Shop.

5.3 Profiling in the Internet Shop consists in automatic analysis or prediction of a given person's behaviour on the website of the Internet Shop, e.g. through adding a particular Product to the basket, browsing the page of a particular Product in the Internet Shop or through analysis of the previous history of purchases made in the Internet Shop. The condition of such profiling is that the Administrator has the personal data of the person in question in order to be able to send him/her e.g. a discount code.

5.4 The data subject shall have the right not to be subject to a decision which is based solely on automated processing, including profiling, and which produces legal effects with regard to the person concerned or significantly affects the person in a similar manner.

6. RIGHTS OF THE DATA SUBJECT


6.1 Right of access, rectification, restriction, erasure or portability - the data subject shall have the right to request from the Controller access to his/her personal data, their rectification, erasure ("right to be forgotten") or restriction of processing and shall have the right to object to the processing, as well as the right to portability of his/her data. The detailed conditions for exercising the rights indicated above are indicated in Articles 15-21 of the RODO Regulation.

6.2 Right to withdraw consent at any time - the person whose data are processed by the Administrator on the basis of an expressed consent (pursuant to Article 6(1)(a) or Article 9(2)(a) of the RODO Regulation), has the right to withdraw the consent at any time without affecting the legality of the processing performed on the basis of the consent before its withdrawal.

6.3 Right to lodge a complaint to the supervisory authority - the person whose data are processed by the Controller has the right to lodge a complaint to the supervisory authority in the manner and mode specified in the provisions of the RODO Regulation and Polish law, in particular the Personal Data Protection Act. The supervisory authority in Poland is the President of the Office for Personal Data Protection.

6.4 Right to object - The data subject shall have the right to object at any time - on grounds relating to his/her particular situation - to the processing of personal data concerning him/her based on Article 6(1)(e) (public interest or tasks) or (f) (legitimate interest of the controller), including profiling under these provisions. The controller shall in that case no longer be permitted to process those personal data unless the controller 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 claims.

6.5 Right to object to direct marketing - where personal data are processed for the purposes of direct marketing, the data subject shall have the right to object at any time to the processing of personal data concerning him or her for such marketing, 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 paragraph of the Privacy Policy, the Administrator may be contacted by sending a relevant message in writing or by e-mail to the address of the Administrator indicated at the beginning of the Privacy Policy or by using the contact form available on the website of the Internet Shop.

7. COOKIES IN THE INTERNET SHOP AND ANALYTICS


7.1 Cookies are small information in the form of text files sent by a server and stored on the side of the person visiting the website of the Online Shop (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 Shop). Detailed information on Cookies as well as the history of their creation can be found, among others, here: https://pl.wikipedia.org/wiki/HTTP_cookie.

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

By their provider:

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

2) owned by third parties (other than the Administrator)

Due to their storage time on the device of the person visiting the Internet shop's website:

1) session (stored until logging out of the Internet Shop or switching off the Internet browser) and

2) permanent (stored for a specified time, defined by the parameters of each file or until manual removal)

Due to the purpose of their use:

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

2) functional/preferential (enabling adjustment of the Internet Shop website to the preferences of the person visiting the website),

3) analytical and performance (gathering information on the manner of use of the Internet Shop website),

4) marketing, advertising and social (gathering information about the person visiting the Internet Shop website in order to display personalised advertisements to that person and carry out other marketing activities, including on websites separate from the Internet Shop website, such as social networking sites

7.3 The Administrator can process data contained in Cookies when visitors use the website of the Internet Shop for the following specific purposes:

Purposes of using cookies in the Administrator's Internet Shop

identifying Service Recipients as logged in to the Online Shop and showing that they are logged in (essential cookies)

Remembering about Products added to the basket in order to place the Order (cookies necessary)

save data from completed Order Forms, surveys or login data to the Online Shop (essential and/or functional/preference cookies)

adjust the content of the website of the Internet Shop to individual preferences of the Service Recipient (e.g. as regards colours, font size, page layout) and optimise the use of the pages of the Internet Shop (functional/preferential Cookies)

keep anonymous statistics presenting the manner of use of the pages of the Internet Shop (statistical cookies files)

7.4 Checking in the most popular web browsers which cookies (including the duration of cookies and their provider) are sent at a given moment by the website of the Internet Shop is possible in the following way:

In the Chrome browser:

(1) in the address bar, click on the padlock icon on the left, (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 box "Tracking cookies between sites", "Social media tracking elements" or "Content with tracking elements"

In Internet Explorer:

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

In the Opera browser:

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

In the Safari browser:

(1) click on the "Preferences" menu, (2) go to the "Privacy" tab, (3) click on the "Manage site data" box

Irrespective of the browser, using the tools available, for example, at: https://www.cookiemetrix.com/ or: https://www.cookie-checker.com/

7.5 By default, most web browsers available on the market accept the storage of Cookies. You can determine the conditions for the use of Cookies by means of the settings of your own Internet browser. 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 functionality of the Online Store (for example, it may not be possible to follow the path of the Order through the Order Form due to failure to remember the Products in the shopping cart during the subsequent steps of submitting the Order).

7.6 Browser settings concerning Cookies are important from the point of view of consent for the use of Cookies by our Online Shop - in accordance with the law, such consent may also be expressed through your Internet browser settings. Detailed information about changing the settings for cookies and their independent deletion 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):

7.7. in the Chrome browser

7.8. Firefox browser

7.9. the Internet Explorer browser

7.10. the Opera browser

7.11. the Safari browser

7.12. the Microsoft Edge browser

7.13 The Administrator may use Google Analytics and Universal Analytics services provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). These services help the Administrator keep statistics and analyse the traffic in the Internet Shop. The collected data are processed by the above services to generate statistics which help administer the Internet Shop and analyse the traffic in the Internet Shop. These data are of collective character. When using the above services in the Internet Shop, the Administrator collects data such as sources and medium of obtaining visitors to the Internet Shop and their behaviour on the website of the Internet Shop, information on the devices and browsers from which they visit the page, IP and domain, geographical data and demographic data (age, gender) and interests.

7.14. It is possible to block in an easy way a given person's access to Google Analytics information about his/her activity on the website of the Internet Shop - for this purpose, you can, for example, install a browser add-on provided by Google Ireland Ltd. available here: https://tools.google.com/dlpage/gaoptout?hl=pl.

8. FINAL PROVISIONS


8.1 The Internet Shop can contain links to other websites. The Administrator encourages the Customer, after navigating to other websites, to read the privacy policy established there. This privacy policy applies only to the Administrator's Internet Shop.

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