RODO

Privacy Policy and Cookie Policy
for websites operated by ELBO sp. z o.o.

Privacy protection

ELBO sp. z o.o. hereinafter referred to as “ELBO” or the “Controller”, attaches particular importance to respecting the privacy of Users visiting websites administered by ELBO, hereinafter referred to as the “Websites”. Data collected in log files is used solely for the purpose of administering the Websites. Servers automatically record data such as the page request sent by the User, the date and time of the request and response, device data, for example hardware model, browser type, browser language, and operating system type. Most logs, server logs, are not linked to any specific User. Any User data obtained via the Websites is protected in accordance with applicable law.

Data collection

1. All data originating from Users of the Websites is collected in two ways:
2. information provided voluntarily by the User:

We ask Users using registration and contact forms to provide personal data for the purpose of registration, creating a permanent account in the online store, submitting a complaint, or making an inquiry. During registration, the Controller informs the User which data listed in the registration form is necessary for the provision of services and indicates which data in the form is additional and does not affect the suspension of the registration process.

2. information obtained while using the Websites, which may include:
3. a) IP address – every computer connected to the Internet is assigned a unique number, i.e. an IP address; on this basis, it is possible, for example, to identify the country from which a given User connects to the network. ELBO reserves the right to store additional internal logs within the Website that connect the IP address with the customer account. These logs are used solely to analyse possible technical problems during registration, login, and use of the Website.
4. b) text files, known as “cookies”, sent to the User’s computer when visiting the website. Cookies store only the data required for the proper operation of the website, including identification of the currently logged-in User. The User’s personal data may be displayed in the content of web pages when visiting an account in the online store.
5. The Controller of the data contained in the Websites is ELBO sp. z o.o. with its registered office in Jelcz-Laskowice, ul. Oleśnicka 7a, 55-220 Jelcz-Laskowice, entered in the register of entrepreneurs maintained by the District Court for Wrocław-Fabryczna in Wrocław, 9th Commercial Division of the National Court Register, under KRS number 0000290164, with share capital of PLN 2,050,000.00, REGON: 020590115, NIP: 9121824839.

The Controller processes personal data in accordance with the consent granted by the User and in compliance with applicable legal provisions, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, and the Act of 18 July 2002 on the provision of electronic services.

Cookie mechanism

The term “cookie” used in this document refers to cookies and other similar tools described in Directive 2009/136/EC of the European Parliament concerning the processing of personal data and the protection of privacy in the electronic communications sector, the Directive on privacy and electronic communications, and Article 173 of the Telecommunications Law.

1. A web browser may store cookies on the computer’s hard drive. Cookies contain information necessary for the proper functioning of the Websites. Cookies are small files saved on the User’s end device, used to identify the User’s browser while using our Websites. Cookies provide the Controller with statistical information about User traffic, User activity, and the manner in which the Websites are used. They allow content and services to be adjusted to the User’s preferences.
2. The content of cookies does not allow the User to be identified.

• Cookies do not process or store personal data of Users of the Websites.

The cookie mechanism is not used to obtain any information about Users, except for information about their behaviour on the Website. ELBO sp. z o.o. with its registered office in Jelcz-Laskowice, ul. Oleśnicka 7a, 55-220 Jelcz-Laskowice, entered in the register of entrepreneurs maintained by the District Court for Wrocław-Fabryczna in Wrocław, 9th Commercial Division of the National Court Register, under KRS number 0000290164, with share capital of PLN 2,050,000.00, REGON: 020590115, NIP: 9121824839.

1. ELBO uses Google tools to track the activity of Users of the Websites. In this case, cookies are used to store information, for example about the start time of the User’s current visit, whether the User has previously visited the website, and from which website the User arrived at the website administered by ELBO.
2. ELBO stores cookies on Users’ computers for the purpose of:

• properly adapting the Websites to Users’ needs and optimising the use of websites;
• remembering the User’s preferences and individual settings, allowing the User’s device to be recognised and the website to be displayed appropriately according to their needs;
• creating Website viewing statistics, which help to understand how Users use the websites and make it possible to improve their structure and content;
• maintaining the User’s session on the Website after logging in, so that the User does not have to re-enter their login and password on every subpage of the Website;
• saving shopping cart data in the online store so that it is not lost when the User visits the Website again.

1. Types of cookies used on Websites administered by ELBO.
   1. Due to the lifetime of cookies and other similar technologies, the following files are used:
   2. a) “session cookies”, i.e. temporary files stored on the User’s end device until logging out, leaving the website, or closing the software, i.e. the web browser.
      b) “persistent cookies”, which are stored on the User’s end device for the period specified in the cookie parameters or until they are deleted by the User.
   3. Due to the purpose served by cookies and other similar technologies, the following types of files are used:
   4. a) “necessary” cookies, enabling the use of services available within the Website, for example authentication cookies used for services requiring authentication within the Website;
      b) cookies used to ensure security, for example cookies used to detect abuse in the field of authentication within the Website;
      c) “performance” cookies, enabling the collection of information about how the Website pages are used;
      d) “functional” cookies, enabling the Website to remember settings selected by the User and personalise the User interface, for example in terms of selected language or region, font size, website appearance, etc.;
      e) “advertising” cookies, enabling the delivery of advertising content optimally tailored to Users’ interests.

• The User has the option to configure their web browser so as to completely or partially disable the storage of cookies on the computer’s hard drive. These settings may be changed in particular in such a way as to block the automatic handling of cookies in the web browser settings or to inform the User each time cookies are placed on the User’s device.
• ELBO informs that restrictions on the use of cookies may affect some functionalities available on the Website pages.

1. Detailed information about the possibility and methods of handling cookies is available in the software settings, i.e. the web browser, in the “Help” section and at http://wszystkoociasteczkach.pl/.

Processing of personal data

1. Data collected within the Websites is used to provide specific services to our Users, for administrative and statistical purposes, and to protect the Websites.
2. ELBO collects and processes personal data for purposes related to necessary activities connected with the performance of an agreement. Each time, the purpose, scope, and recipients of data processed by the Controller result from actions taken by the Customer.

• The Controller informs that personal data will be processed for the following purposes:
• concluding and performing agreements pursuant to Article 6(1)(b) of the GDPR, for the duration of such agreements and until the expiry of the limitation periods for pursuing claims;
• handling complaints and claims pursuant to Article 6(1)(c) of the GDPR, for one year after the expiry of the warranty period or settlement of the complaint;
• pursuing claims related to a concluded agreement pursuant to Article 6(1)(f) of the GDPR, where the legitimate purpose is the pursuit of receivables, until the final completion of proceedings, including enforcement proceedings;
• archiving accounting documents pursuant to Article 6(1)(c) of the GDPR until the expiry of the tax liability limitation period;
• conducting marketing activities concerning own products and services without the use of electronic means of communication pursuant to Article 6(1)(f) of the GDPR, where the legitimate purpose is to conduct marketing activities promoting the business activity, until an objection is raised;
• where necessary to protect the vital interests of the data subject or another natural person pursuant to Article 6(1)(d) of the GDPR;

Furthermore:

• if you have given your consent, also for the purpose of conducting marketing activities concerning own products and services using electronic means of communication, pursuant to Article 6(1)(f) of the GDPR and provisions of other laws requiring consent for such activities, until consent for such activities is withdrawn or an objection is raised, whichever occurs first.
• for statistical purposes pursuant to Article 6(1)(f) of the GDPR, where the legitimate purpose is to possess information about statistics of activities conducted by the Controller, which allows the improvement of the business activity;
• handling submissions made via the contact form and other requests, including ensuring accountability of conducted activities, where the legitimate purpose is to respond to submissions and inquiries made via the contact form or in another form, including storing sensitive requests and responses provided in order to maintain the principle of accountability, for a period of 3 years.

1. The Controller informs that data will be transferred to recipients on the basis of appropriate data processing agreements only for the purposes of proper business operation, i.e.:

• entities providing postal or courier services;
• entities enabling us to perform remote payment operations;
• banks, where settlements need to be made;
• state authorities or other entities authorised under legal provisions;
• entities supporting the Controller in its business activity on request, in particular providers of external systems supporting the Controller’s activity.

1. Your personal data will not be transferred to other recipients in a third country or to international organisations.
2. The Controller may process the following personal data of Customers: name and surname, e-mail address, contact telephone number, IP address, delivery address, street, house number, apartment number, postal code, town/city, country, residential/business/registered office address, if different from the delivery address. In the case of Service Recipients or Customers who are not consumers, the Controller may additionally process the company name and tax identification number, NIP, of the Service Recipient or Customer.

• Where the purpose of personal data processing is marketing activities and the provision of commercial information, including, for example, receiving messages in the form of a free newsletter, information about promotions, sales, events, and competitions organised by ELBO, the legal basis for processing is the consent given by the data subject. When asking for consent, we inform the User about the exact purpose of data processing in the information clause. The User’s personal data will be processed until consent is withdrawn. ELBO reserves that, due to the synchronisation of activities, pseudonymisation/anonymisation of the User’s data from the system may take up to 72 hours from the moment an objection is raised.
• ELBO may collect and process Users’ data in the form of an e-mail address and possibly other data provided voluntarily by the User, for example name and surname, for the purpose of submitting a complaint or presenting comments. In such a case, providing personal data is voluntary but necessary to consider the complaint or answer the question. By providing personal data, the User agrees to the processing of personal data solely for the purposes of considering the complaint or answering the question.

1. Data collected within the Websites will not be sold or made available to other institutions, organisations, or persons who are not employees or permanent associates of ELBO. Access to data is held by companies cooperating with ELBO and supporting system operation, as well as Google Inc. through the use of data for the statistical functionalities of Google Analytics and advertising functionalities of Google AdWords.
2. Your personal data will not be subject to profiling consisting of the analysis of transactional and personal data, and no binding decisions will be made concerning you in an automated manner.
3. Based on information obtained within the Websites, ELBO may prepare aggregate statistical summaries that may be disclosed to third parties. Such summaries do not contain any data allowing the identification of individual Users.

• ELBO ensures that Users can exercise the rights arising from Article 173 of the Telecommunications Law and Article 32 of the Act of 29 August 1997, as well as Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, in particular: the right to access and correct their data, the right to delete data, the right to be forgotten, or restrict its processing, the right to object to data processing for purposes other than those indicated above, the right to data portability, the right to withdraw consent at any time, and the right to lodge a complaint with the supervisory authority, which is the President of the Personal Data Protection Office. Statements regarding the exercise of the above rights and any comments should be sent to the e-mail address: elbo@elbo.wroc.pl

Security

1. ELBO makes every effort to protect the Websites against unauthorised access by third parties. For this purpose, firewalls, server security devices, encryption devices, and physical security measures are used, among others. At the same time, we draw Users’ attention to the need not to disclose their registration data to third parties, in particular not to disclose the account password, and to use the “log out” option after finishing the use of content and services offered by our Websites.
2. ELBO Websites contain links to other websites. We recommend that after going to other websites, Users read the privacy policy applicable there. ELBO is not responsible for the privacy policies of websites to which links are placed on the Website pages.

Changes

In the event of changes to the Privacy Policy applicable to the Websites, ELBO will publish the appropriate modification on this subpage.