PERSONAL DATA ADMINISTRATOR
The administrator of Personal Data processed via the Website or other channels of communication with the Customer is Vershold Poland Sp. z o. o. with its registered office in Warsaw, address: ul. Żwirki i Wigury 16A, 02-092 Warsaw, entered into the Register of Entrepreneurs kept by the District Court for the Capital City of Warsaw Warszawa in Warsaw, 14th Division of the National Court Register, under KRS number 0000629221, REGON 142114475; e-mail address: firstname.lastname@example.org, +48 603 124 666 (connection fee according to the relevant operator's price list), hereinafter referred to as "Vershold " .
CONTACT WITH THE ADMINISTRATOR OF PERSONAL DATA
The Website User can contact Vershold directly at any time via:
- e-mail: email@example.com;
- a written letter sent by post to the following address: Vershold Poland Sp. z o. o., address: ul. Żwirki i Wigury 16A, 02-092 Warsaw;
- by phone at +48 22 376 27 91 (connection fee according to the price list of the relevant operator);
- fanpage of the Online Store on the Facebook social network.
In the event that the Customer contacts Vershold via one of the above-mentioned methods, Vershold may request the Customer to provide additional, further information and Personal Data in order to respond. Providing information and Personal Data is voluntary, but it may be necessary to perform activities or obtain information that is of interest to the Customer. If the Customer contacts Vershold using the form, Vershold may request the Customer to provide Personal Data in order to confirm the Customer's identity and enable contact in a given matter.
Vershold stores correspondence with the Customer in order to answer questions regarding the implementation, complaint proceedings and for statistical purposes. Personal Data processed in this way will not be used to communicate with the Customer for purposes other than the execution of the application.
All commercial information related to the activities of Vershold may be sent only in accordance with the prior consent of the Customer expressed in order to conclude and perform the contract for the provision of the Newsletter service .
PROCESSING OF PERSONAL DATA
SECURITY OF PERSONAL DATA
Vershold processes Personal Data in accordance with the Act of May 10, 2018 on the protection of personal data (Journal of Laws of 2018, item 1000) and Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 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 (Journal of Laws UE. L No. 119, p. 1) (hereinafter also: "GDPR") and having regard to the provisions of the Act of 18 July 2002 on the provision of electronic services (Journal of Laws 2020.344, i.e. of 2020.03.03).
Vershold uses appropriate technical and organizational measures to ensure the protection of the processed Personal Data, including security measures of a programming nature (e.g. data encryption system) adequate to the threats and categories of data protected. In particular, we protect Personal Data against disclosure to unauthorized persons, processing in violation of applicable regulations and change, loss, damage or destruction. Vershold exercises constant control over the processing of Personal Data and limits access to Personal Data as much as possible.
Vershold takes special care to protect the interests of the persons to whom the Personal Data relates, and in particular ensures that the collected Personal Data are:
- processed lawfully, fairly and in a transparent manner for the data subject;
- collected for specific, explicit and legitimate purposes and not further processed in a manner incompatible with these purposes;
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- correct and updated as necessary;
- kept in a form that allows identification of the data subject for no longer than is necessary for the purposes for which the data is processed;
- processed in a manner that ensures adequate security of Personal Data, including protection against unauthorized or unlawful processing and accidental loss, destruction or damage, using appropriate technical or organizational measures.
SCOPE AND PURPOSES OF PERSONAL DATA PROCESSING
Bearing in mind the applicable regulations and, above all, the security of Customers' Personal Data in each case of Personal Data processing, the purpose and scope of data processing result from the Customer's consent or legal provisions and are clarified as a result of the Customer's actions on the Website or as part of other communication channels with a client.
Vershold protects the Personal Data of Customers, persons visiting the Online Store and persons who provide Personal Data via other communication channels. In particular, Vershold protects the Personal Data of users of www.facebook.com and any other websites marked or co-branded with the Facebook brand, the rules of operation of which are based on the provisions: https://www.facebook.com/legal/terms , provided by Facebook Inc. . or Facebook Ireland Limited, also using the Facebook Lead Ads function aimed at direct marketing of Vershold's own products or services. The rules for processing Personal Data by Facebook are available at: https://www.facebook.com/policy.php. Vershold has no influence on the content of the rules of processing Personal Data by Facebook.
Vershold may process Personal Data provided in the contact form, provided in the course of using the Website, including in the course of using the Account, submitted as part of submitting inquiries and complaints, in the form for sending the Newsletter, when issuing opinions, as well as other data obtained in based on the Customer's activity on the Website. Vershold may process Personal Data obtained via the Website or other channels of communication with the Customer, including those processed automatically in the course of using the Website to the extent that information obtained through the technology used may be considered Personal Data (data on the use of the Website website, operating system version data, screen resolution data,
Therefore, Vershold may process the following Customer Personal Data: name and surname, nickname, e-mail address, contact telephone number, delivery address (street, house number, apartment number, zip code, city, country), address of residence/business activity/registered office company (if different from the delivery address), bank account number. In addition, the following Personal Data may be collected: information contained in the User's profile, confirmation of the status of a Private User, preferences regarding the Customer Account, IP address, operating system, browser type, browser version, browser configuration, name of the Internet provider and other information regarding the type of computer and Internet connections used to identify the type of device, connect to the Website,
Vershold processes Personal Data only for the following purposes:
- enabling the placing of orders for products and services on the Website and the processing of orders;
- handling complaints and possible other claims,
- enabling personalized use of the Website (e.g. adjusting the content of offers to the preferences of customers);
- managing, operating, maintaining and improving the operation of the Website;
- conducting analysis and research of customer behavior;
- presenting customer opinions about products;
- answering customers' questions and handling applications sent to Vershold;
- enabling Customers to receive information on products and services by e-mail, telephone, fax, by sending a Newsletter, SMS and MMS messages (direct marketing);
- sending messages dedicated to Customers (e.g. sending reminders, technical information, updates, security alerts, administrative messages and service bulletins);
- enabling the transfer of prizes, sending surveys, information about lotteries, contests or other promotional activities;
- in order to perform the contract for the provision of the Newsletter service, Personal Data may also be processed for marketing purposes of products or services of entities with which Vershold cooperates.
LEGAL BASIS FOR PROCESSING PERSONAL DATA BY VERSHOLD
- the need to perform a contract to which the Customer is a party or to take action at his request before its conclusion (pursuant to Article 6(1)(b) of the GDPR), including, among others, execution of orders, settlements, communication related to the provision of services, conclusion of a contract for the provision of electronic services, conclusion of a sales contract, conclusion of a contract for the provision of the Newsletter service;
- Vershold's legitimate interest (pursuant to Article 6(1)(f) of the GDPR) - answering Customers' questions and handling messages sent to Vershold via the form available on the Website in the "Contact" tab or via chat and in connection with issuing opinions about the product, improving the service of ordering goods via the Website; securing the pursuit of possible claims and defense against claims in connection with Vershold's business activity; complaints service; creating analyzes and summaries for internal needs; managing, operating, maintaining and improving the operation of the Website; informing the Customer about updates or changes introduced to the services; adapting the content of the Website or offers to the individual preferences of customers;
- the Customer's consent (pursuant to Article 6(1)(a) of the GDPR) - to the extent that the Customer agrees to the presentation, creation, granting and implementation of advertisements, offers or promotions (rebates) dedicated to the Customer, which are based solely on on automated processing, including profiling, which may significantly affect the Customer's consumer decisions;
- the Customer's consent (pursuant to Article 6(1)(a) of the GDPR) - to the extent that the Customer agrees to the publication of his opinion about the product via the Website and consents to the processing of personal data in connection with such an opinion . The content of the opinion and the pseudonym are subject to publication. Consent to the processing of personal data in connection with the publication of an opinion may be withdrawn at any time, however, it does not affect the lawfulness of processing before consent is withdrawn;
- fulfillment of obligations imposed under tax and accounting regulations (pursuant to Article 6(1)(c) of the GDPR and relevant tax or accounting regulations) to the extent that Vershold processes Personal Data in performance of tax obligations (keeping books of accounts, issuing documents accountants).
To the extent that Vershold's partners may have direct access to Customers' personal data - the legal basis for such processing is the Customer's voluntary consent (Article 6(1)(a) of the GDPR).
For other (other) purposes, the Customer's Personal Data may be processed on the basis of:
- voluntary consents (Article 6(1)(a) of the GDPR);
- applicable law (Article 6(1)(c) of the GDPR);
- indispensability for purposes other than those listed above resulting from legitimate interests pursued by Vershold (Article 6(1)(f) of the GDPR).
VOLUNTARY PROVISION OF PERSONAL DATA
Vershold in each case means the Personal Data required for the performance of individual services or for concluding a relevant contract.
Providing Personal Data by the Customer in the Online Store is voluntary, with the proviso that providing them is necessary to use certain functionalities of the Online Store, including the conclusion and performance of the Sales Agreement, Account registration or the conclusion and performance of the Agreement for the Provision of Services.
The consequence of not providing Personal Data may be the inability to effectively perform the above activities.
Providing Personal Data in the scope resulting from the contact form and chat (name and e-mail address) is voluntary, but necessary in order to contact the Customer and provide an answer. Providing a contact telephone number is voluntary and is not necessary in order to contact the Customer and provide an answer. Providing other (not required) Personal Data is voluntary.
Providing Personal Data to the extent resulting from issuing an opinion on the product (nickname) is voluntary, but necessary in order to issue an opinion on the Website. The content of the opinion and the pseudonym are subject to publication. Consent to the processing of Personal Data in connection with the publication of an opinion may be withdrawn at any time, however, it does not affect the lawfulness of processing before consent is withdrawn.
Providing Personal Data to the extent resulting from the Newsletter service (e-mail address) is voluntary, but necessary for the provision of the Newsletter service.
TRANSFER OF CUSTOMERS' PERSONAL DATA TO THIRD PARTIES
Vershold does not sell, exchange, rent, disclose, transfer or otherwise make available Customers' Personal Data, except when the Customer gives its prior consent and except for the circumstances described below.
Vershold may transfer Customers' Personal Data to the following entities:
- a selected carrier or intermediary performing shipments at the request of Vershold - in the case of a Customer who uses the Online Store with the method of delivery by post or courier;
- a selected entity servicing payments in the Online Store - in the case of a Customer who uses the Online Store with the method of electronic payments or by payment card;
- providers of hosting or ICT services, companies servicing software, supporting Vershold in marketing campaigns, as well as providers of legal and consulting services;
- entities using cookies in the Online Store;
- providers of legal services (in particular law firms and debt collection companies) as well as audit and advisory services;
- other entities to which Vershold entrusted the processing of Personal Data while maintaining a full guarantee of securing Customers' Personal Data.
Each time, the catalog of recipients of personal data processed by Vershold results primarily from the scope of services used by the Customer and from the Customer's consent, or from legal provisions, and is clarified as a result of the Customer's actions in the Online Store.
Personal Data may be made available by Vershold if it is necessary to protect the rights or safety of Vershold, other Customers or third parties - as part of the implementation of the law.
TRANSFER OF CLIENTS' PERSONAL DATA TO THIRD COUNTRIES (OUTSIDE THE EUROPEAN ECONOMIC AREA)
The collected Personal Data is stored and processed within the European Economic Area (hereinafter also: EEA), with the proviso that information obtained by means of cookies may be saved outside the EEA, and in exceptional cases the full IP address may be transferred outside the EEA and shortened there. Personal Data may be made available to entities located outside the European Union or the European Economic Area. Such entities may be located in countries where applicable data protection law provides a lower level of protection than in your country of residence. In the case of transferring data to countries outside the EEA whose level of data protection has not been recognized as appropriate by the European Commission,
PROFILING OF PERSONAL DATA
Personal Data in the form of data entered into the contact form, chat, opinions, Account registration and placing orders will not be profiled. Personal Data collected using cookies, with the consent of the Customer, may be processed in order to present, create, grant and implement advertisements, offers or promotions regarding Vershold products or services to the Customer, in a manner tailored to the Customer's preferences as a result of automated decision-making, which may produce legal effects or similarly significantly affect the Customer. Such an operation is profiling of personal data.
RIGHTS OF CLIENTS REGARDING THE PROCESSING OF PERSONAL DATA
Each person has the right to control the processing of data concerning them, including the right to request their updating, correction and deletion, the right to transfer personal data and the right to object to the processing of personal data - the implementation and scope of these rights are specified in the provisions of the GDPR. Requests to exercise the rights can be submitted using the Administrator's contact details (above).
Right of access and rectification
Each Customer has the right to access their Personal Data, including in particular the right to information: what Personal Data are processed by Vershold, what source they come from, for what purposes they are used and information about the identity of persons/entities to whom the data has been provided. The customer also has the right to change the content of his personal data - to correct false or incomplete personal data.
Right to withdraw consent
Each Customer has the right to withdraw any consent given to Vershold at any time, however, the withdrawal of consent does not affect the processing carried out by the Administrator in accordance with the law before its withdrawal.
Right to restriction of data
Each customer has the right to limit processing when one of the circumstances provided for in art. 18 of the GDPR, including in particular, the Customer questions the correctness of personal data, the processing is unlawful, and the Customer opposes the removal of personal data, requesting the restriction of their use instead, the Customer has objected to processing - until it is determined whether the legitimate grounds are overriding the grounds for the Customer's objection. If processing has been restricted, such Personal Data may be processed, with the exception of storage, only with the consent of the Customer, or to establish, pursue or defend claims, or to protect the rights of another natural or legal person, or for important reasons of public interest of the Union or a Member State.
Right to object
Each Customer has the right to object to the processing of Personal Data concerning the Customer carried out in order to implement the legitimate interests of the Administrator or a third party (if there are no other valid legitimate grounds for processing overriding the interests of the Customer), including profiling based on these provisions. If Personal Data is processed for the purposes of direct marketing, the Customer has the right to object at any time to the processing of their Personal Data for the purposes of such marketing, including profiling, to the extent that the processing is related to such direct marketing.
The right to delete data
The Customer may request the removal of his Personal Data when one of the circumstances provided for in art. 17 of the GDPR, including in particular when the Personal Data are no longer needed to achieve the purposes for which they were collected and there is no legally justified reason for further processing, or the processing has become unlawful, or the Personal Data had to be deleted in order to fulfill a legal obligation applicable on the territory of the EU or the Republic of Poland.
Right to data portability
Each Customer has the right to transfer Personal Data provided by Vershold and which are processed in an automated manner, and the processing is based on consent or on the basis of a contract. The customer may also ask Vershold to transfer the data directly to another data controller, if it is technically feasible.
Right to lodge a complaint
Each customer has the right to lodge a complaint to the President of the Office for Personal Data Protection when he considers that the processing of Personal Data violates the law. Contact details to the Office: https://uodo.gov.pl/pl/p/kontakt
PERIOD OF STORAGE OF PERSONAL DATA
Personal Data may be processed by Vershold for the period of:
- in the case of the provision of services by the Website - for the entire duration of the contract for the provision of electronic services; if the contract is terminated, Personal Data will be stored for a period of 3 years from the date of termination of the contract for the provision of electronic services;
- for the duration of using the Website in the case of Personal Data in the form of data on the use of the Website, operating system version data, screen resolution data, data collected using cookies or other technologies used to track Users' activity, device IP data, location, web browser data;
- if Personal Data is processed in order to pursue claims or defend against claims (e.g. in debt collection proceedings) - for the period of limitation of claims resulting from the provisions of the Civil Code;
- all Personal Data processed for accounting purposes and for tax reasons are processed for 5 years counted from the end of the calendar year in which the tax obligation arose;
- Personal Data will be processed by Vershold to the extent that the basis for the processing of Personal Data is the Customer's consent until its withdrawal, unless the period indicated above expires earlier.
After the expiry of the above-mentioned periods, Personal Data is deleted or anonymized.
In order to ensure the accountability of the obligations arising from the GDPR, Personal Data may be stored indefinitely, but this will take place in exceptional situations (for example, in the event of an objection, Vershold will store Personal Data in order to demonstrate that the User's request has been met).
Cookies are small text information in the form of text files, sent by the server and saved on the side of the Online Store User (e.g. on the hard drive of a computer, laptop or smartphone memory card - depending on what device the Online Store User uses). Cookies can be divided into first parties (first-party cookies) or third parties (third-party cookies). Own cookies are files placed in the User's browser directly by the Online Store website that he visited, while third party cookies are placed by partners of the visited Online Store website. The Online Store uses first party cookies in order to:
- identifying Customers as logged in to the Online Store and showing that they are logged in;
- remembering Products added to the basket;
- remembering data from completed Order Forms, surveys or login data to the Online Store; adjusting the content of the Online Store website to the individual preferences of the Customer and optimizing the use of the Online Store pages;
- keeping anonymous statistics showing how the Online Store website is used.
In the scope of its marketing activities, Vershold uses digital marketing tools: Google Ads, Meta Ads, Mailchimp, Shopify Marketing Tools, which use third party cookies in order to:
- building groups of recipients;
- presenting relevant advertisements and messages;
- improving the quality of the presented advertisements and messages;
It is possible to block the storage of cookies on the device, however, blocking first party cookies may have a negative impact on the operation of the Online Store. Cookie settings can be controlled and configured in a web browser. The method of blocking and deleting cookies can be found in the help panel of the web browser used.
Google Analytics 4 - this is a tool with which Vershold keeps anonymous statistics showing the behavior of Users in the Online Store.
- Google Analytics 4 uses first party cookies, which are not shared with third parties;
- Google Analytics 4 does not collect personal data;
- Using Google Analytics 4, Vershold can create an anonymous Customer ID, which will be combined with the Customer's data provided during registration or login in order to better identify the Customer and improve the quality of the Online Store's services.
Privacy and data security in Google Analytics:
It is possible to generally prevent the transfer of data from the Customer's device to Google Analytics 4 using cookies (including the transfer of the IP address) by downloading the browser plug-in available at the following address provided by Google Inc and installing it:
LINKS TO OTHER WEBSITES