Privacy policy

TABLE OF CONTENTS:

1. GENERAL

2. BASES FOR DATA PROCESSING

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

4. RECIPIENTS OF DATA 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 Store is for information purposes only, which means it is not a source of obligations for Service Recipients or Customers of the Online Store. The Privacy Policy contains primarily the principles regarding the processing of personal data by the Controller in the Online Store, including the bases, purposes, and scope of processing personal data and the rights of individuals whose data are processed, as well as information regarding the use in the Online Store of cookies and analytical tools.

1.2. The controller of personal data collected through the Online Store is ETHNE limited liability company, entered into the Register of Entrepreneurs of the National Court Register under KRS number: 0000971781, with the address of business activity and address for service: ul. Hoża 86/410, 00-682 Warsaw, Poland, VAT no.: 7011087899, REGON: 522029577, e-mail address: , phone number: +48 22 100 60 88 – hereinafter referred to as the "Controller", being also the Service Provider of the Online Store and the Seller.

1.3. The controller is not required to appoint a data protection officer and has not done so.

1.4. Personal data in the Online Store is processed by the Controller in accordance with applicable law, in particular with 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 and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) – hereinafter referred to as "GDPR" or the "GDPR Regulation". Official GDPR text:

1.5. The use of the Online Store, including making purchases, is voluntary. Likewise, providing personal data by a Service Recipient or Customer using the Online Store is voluntary, with two exceptions: (1) concluding agreements with the Controller – non-provision, in the cases and scope indicated on the Online Store's website and in the Online Store Regulations and this privacy policy, of the personal data necessary for the conclusion and performance of a Sales Agreement or agreement for the provision of Electronic Services with the Controller results in the impossibility of concluding such an agreement. Providing personal data is, in such a case, a contractual requirement and, if the data subject wishes to conclude a given agreement with the Controller, they are obliged to provide the required data. The scope of data required to conclude a contract is each time indicated on the Online Store's website and in the Online Store Regulations; (2) statutory obligations of the Controller – providing personal data is a statutory requirement resulting from universally applicable legal provisions imposing on the Controller the obligation to process personal data (e.g. for data processing in order to keep tax or accounting books) and failure to provide them will prevent the Controller from fulfilling those obligations.

1.6. The Controller takes special care to protect the interests of individuals whose personal data is processed, and in particular is responsible and ensures that the data collected is: (1) processed in accordance with the law; (2) collected for designated, lawful purposes and not subjected to further processing inconsistent with those purposes; (3) substantively correct and adequate in relation to the purposes for which they are processed; (4) stored in a form that permits identification of the persons to whom they relate, no longer than is necessary to achieve the purpose of processing; and (5) processed in a manner that ensures adequate security of personal data, including protection against unauthorized or unlawful processing as well as accidental loss, destruction, or damage, by means of appropriate technical or organizational measures.

1.7. Taking into account the nature, scope, context and purposes of processing as well as the risk of violation of the rights or freedoms of natural persons of varying likelihood and severity, the Controller implements appropriate technical and organizational measures so that processing is carried out in accordance with this regulation and that they are able to demonstrate it. These measures shall be reviewed and updated as necessary. The Controller applies technical measures to prevent unauthorized persons from acquiring and modifying personal data transmitted electronically.

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

2. BASES FOR DATA PROCESSING

2.1. The Controller is entitled 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 given consent 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 a party or in order to take steps at the request of the data subject prior to entering into a contract; (3) processing is necessary to fulfill a legal obligation incumbent on the Controller; or (4) processing is necessary for purposes resulting from 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 the protection of personal data, in particular when the data subject is a child.

2.2. The processing of personal data by the Controller requires, each time, the existence of at least one of the bases indicated in pt. 2.1 of the privacy policy. Specific bases for processing personal data of Service Recipients and Customers of the Online Store by the Controller are indicated in the next item of the privacy policy – in relation to a specific purpose of personal data processing by the Controller.

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

3.1. Each time, the purpose, basis, period, and recipients of personal data processed by the Controller result from actions taken by a specific Service Recipient or Customer in the Online Store, or by the Controller.

3.2. The Controller may process personal data in the Online Store for the following purposes, on the bases, and for the periods indicated in the table below:

Purpose of data processing	Legal basis for data processing	Data retention period
Execution of the Sales Agreement or the agreement for the provision of Electronic Services or taking action at the request of the data subject before concluding the aforementioned 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	Data is stored for the period necessary for the performance, termination, or other expiration of the concluded Sales Agreement or agreement for the provision of Electronic Services.
Direct marketing	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 of caring for the interests and good image of the Controller, its Online Store, and striving to sell Products	Data is stored for the period of existence of the legitimate interest pursued by the Controller, but no longer than the period of limitation of the Controller’s claims against the data subject due to the business activity conducted by the Controller. The limitation period is defined by law, in particular the Civil Code (basic limitation period for claims related to business activity is three years, and for a sales agreement two years). The Controller may not process data for direct marketing purposes in the event of a valid objection in this regard by the data subject.
Marketing	Article 6(1)(a) of the GDPR (consent) – the data subject has consented to the processing of their personal data for marketing purposes by the Controller	Data is stored until the consent is withdrawn by the data subject for further processing of their data for this purpose.
Expression by the Customer of an opinion on the concluded Sales Agreement	Article 6(1)(a) of the GDPR – the data subject has consented to the processing of their personal data for the purpose of expressing an opinion	Data is stored until the consent is withdrawn by the data subject for further processing of their data for this purpose.
Keeping tax or accounting books	Article 6(1)(c) of the GDPR in conjunction with Article 86 § 1 of the Tax Ordinance Act of 17 January 2017 (Journal of Laws 2017, item 201) or Article 74(2) of the Accounting Act of 30 January 2018 (Journal of Laws 2018, item 395) – processing is necessary for compliance with a legal obligation to which the Controller is subject	Data is stored for the period required by law obliging the Controller to keep tax books (until the expiry of the tax obligation limitation period, unless tax laws state otherwise) or accounting books (5 years from the beginning of the year following the financial year to which the data relates).
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 interest of the controller) – processing is necessary for the purposes of the legitimate interests pursued by the Controller – consisting of establishing, pursuing or defending claims that may be raised by the Controller or that may be raised against the Controller	Data is stored for the period of existence of the legitimate interest pursued by the Controller, but no longer than the limitation period of 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 operation	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 of operating and maintaining the Online Store website	Data is stored for the period of existence of the legitimate interest pursued by the Controller, but no longer than the limitation period of the Controller’s claims against the data subject due to the business activity conducted by the Controller. The limitation period is defined by law, in particular the Civil Code (basic limitation period for claims related to business activity is three years, and for a sales agreement two years).
Keeping statistics and analyzing 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 of keeping statistics and analyzing traffic in the Online Store in order to improve the functioning of the Online Store and increase sales of Products	Data is stored for the period of existence of the legitimate interest pursued by the Controller, but no longer than the limitation period of the Controller’s claims against the data subject due to the business activity conducted by the Controller. The limitation period is defined by law, in particular the Civil Code (basic limitation period for claims related to business activity is three years, and for a sales agreement two years).

4. RECIPIENTS OF DATA IN THE ONLINE STORE

4.1. For the proper functioning of the Online Store, including the implementation of concluded Sales Agreements, it is necessary for the Controller to use the services of external entities (such as e.g., software provider, courier, or entity handling payments). The Controller uses only the services of such processors who provide sufficient guarantees for the implementation of appropriate technical and organizational measures so that processing meets the requirements of the GDPR Regulation and protects the rights of data subjects.

4.2. Transmission of data by the Controller does not occur in every case and not to all recipients or categories of recipients indicated in this Privacy Policy – the Controller transfers data only when needed to achieve the specific purpose of personal data processing and only to the extent necessary to achieve that purpose.

4.2.1. Personal data may be transferred by the Controller to a third country, with the Controller ensuring that, in such a case, this will be to a country ensuring an adequate level of protection – in accordance with the GDPR Regulation; the data subject is entitled to obtain a copy of their data. The Controller transfers collected personal data only if and to the extent necessary to achieve the determined purpose of data processing in line with this Privacy Policy.

4.3. Personal data of Service Recipients and Customers of the Online Store may be transferred to the following recipients or categories of recipients:

4.3.1. Carriers / forwarders / courier brokers / entities handling warehousing and/or shipping process – In the case of a Customer who uses delivery of the Product by postal or courier service in the Online Store, the Controller provides the collected personal data of the Customer to a selected carrier, forwarder or intermediary executing shipments as ordered by the Controller, and if shipping is from an external warehouse – the entity operating the warehouse and/or shipping – to the extent necessary to perform the Product delivery to the Customer.

4.3.2. Entities processing electronic or card payments – In the case of a Customer using electronic or card payment in the Online Store, the Controller provides the collected personal data of the Customer to the selected entity processing such payments on behalf of the Controller in the scope necessary for payment processing.

4.3.3. Lending institutions / lessors – In the case of a Customer using installment or leasing payment in the Online Store, the Controller provides the collected personal data of the Customer to the selected lending institution or lessor executing the respective payment in the Online Store on behalf of the Controller, in the scope necessary for payment processing.

4.3.4. Survey system providers – In the case of a Customer who agreed to express an opinion on a concluded Sales Agreement, the Controller provides the collected personal data of the Customer to the selected entity providing a review survey system regarding Sales Agreements concluded in the Online Store, on behalf of the Controller, in the scope necessary for the Customer to express an opinion through the survey system.

4.3.5. Providers of services supplying the Controller with technical, IT, and organizational solutions enabling the Controller to conduct business activities, including the Online Store and Electronic Services provided via it (especially providers of computer software for the Online Store, e-mail/hosting providers, software providers for company management and providing technical support to the Controller) – the Controller provides the collected personal data of the Customer to the selected provider acting on behalf of the Controller only in case and within the scope necessary to achieve the determined purpose of data processing according to this Privacy Policy.

4.3.6. Providers of accounting, legal and advisory services supplying the Controller with accounting, legal, or advisory support (especially an accounting office, law firm or debt collection company) – the Controller provides the collected personal data of the Customer to the selected provider acting on behalf of the Controller only in case and within the scope necessary to achieve the determined purpose of data processing according to this Privacy Policy.

4.3.7. Providers of plugins, scripts and other tools on the Online Store website enabling the browser of the website visitor to download content or perform functions offered by these providers. In connection with this, it is possible to provide personal data of the visitor (such as IP address, device identifiers, site activity data, contact details, transaction data) to the following entities:

4.3.7.1. Meta Platforms Ireland Ltd. – The Controller uses Facebook service plugins and tools (such as “Like” button, Facebook login, Facebook Pixel), which may result in collection and transfer of visitor data (like device info, activity on site, ads viewed, purchase history) to Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, regardless of whether the visitor has a Facebook account. Details:

4.3.7.2. Klaviyo Inc. – The Controller uses an e-mail and SMS marketing tool, which may result in transmission of personal data (such as name, e-mail address, order history, site activity) to Klaviyo Inc., 125 Summer St, Boston, MA 02111, USA. Details:

4.3.7.3. TrustMate S.A. – The Controller may provide data (such as name, e-mail address, order details) to TrustMate S.A., ul. Bartoszowicka 3, 51-641 Wrocław, for the purpose of collecting and publishing reviews. Details:

4.3.7.4. Netkodo sp. z o.o. (Fakturownia) – In connection with invoice issuance, personal data (such as name, surname, address, Tax ID) may be provided to Netkodo sp. z o.o., ul. Juliana Smulikowskiego 6/8, 00-389 Warsaw. Details:

4.3.7.5. Apilo sp. z o.o. – In connection with integration of the store with external sales platforms, personal data (such as contact data, orders, delivery addresses) may be provided to Apilo sp. z o.o., ul. gen. Józefa Bema 7-9, 87-800 Włocławek. Details:

4.3.7.6. Google Ireland Ltd. / Google LLC – The Controller uses Google tools (Google Analytics, Google Ads, Google reCAPTCHA) which may result in collection and transfer of data (e.g. IP address, site activity data, technical data) to Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, or Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Details:

5. PROFILING IN THE ONLINE STORE

5.1. The GDPR Regulation imposes an obligation on the Controller to inform about automated decision-making, including profiling, as referred to in Article 22(1) and (4) of the GDPR Regulation, and — at least in those cases — relevant information on the rules for its implementation, as well as the significance and anticipated consequences for the data subject. In view of this, the Controller provides in this clause information regarding possible profiling.

5.2. The Controller may use profiling in the Online Store for the purposes of direct marketing, but the decisions made based on it by the Controller are not related to the conclusion or refusal to conclude a Sales Agreement or the possibility of using Electronic Services in the Online Store. The effect of profiling in the Online Store may be, for example, granting a discount, sending a discount code, reminding of unfinished purchases, sending a product proposal that may correspond to the interests or preferences of the person, or sending a suggestion with more favorable terms.

5.3. Profiling in the Online Store consists of automatic analysis or forecast of a given person’s behavior on the Online Store website, e.g., by analyzing the previously undertaken activities (such as adding a product to the cart, browsing a specific page of the Online Store) for the purpose of displaying a product advertisement or offer adjusted to the predicted interests of that person and sending marketing messages.

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

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 processing, as well as the right to data portability. The detailed conditions for the exercise of the above rights are indicated in Articles 15–21 of the GDPR Regulation.

6.2. Right to withdraw consent at any time – the data subject whose data is processed by the Controller based on a granted consent (under 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 processing based on that consent before its withdrawal.

6.3. Right to lodge a complaint with a supervisory authority – the data subject whose data is processed by the Controller has the right to lodge a complaint with a supervisory authority in the manner and in accordance with the procedures specified in the GDPR Regulation 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 at any time to object – on grounds relating to their particular situation – to the processing of their personal data based on Article 6(1)(f) of the GDPR (legitimate interests pursued by the Controller), including profiling on that basis. In such a case, the Controller may no longer process this personal data except where the Controller demonstrates compelling legitimate grounds for the processing overriding the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.

6.5. Right to object to direct marketing – if personal data are processed for direct marketing purposes, the data subject has the right at any time to object to the processing of their personal data for such marketing, including profiling, to the extent that it is related to such direct marketing.

6.6. In order to exercise the rights referred to in this section of the privacy policy, one can contact the Controller by sending a relevant message in writing or by e-mail to the Controller’s address specified at the beginning of the privacy policy or via the contact form available on the Online Store’s website.

7. COOKIES IN THE ONLINE STORE AND ANALYTICS

7.1. Cookies are small text information in the form of text files, sent by the server and stored on the website visitor’s side (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 on cookies as well as the history of their creation can be found, for example, here:

7.2. The Controller may process the data contained in cookies when visitors use the Online Store's website for the following purposes:

7.3. The Controller may process data contained in Cookies when visitors use the Online Store's website for the following specific purposes:

7.4. Checking in the most popular web browsers which Cookies (including the duration of Cookies and their provider) are currently being sent by the Online Store’s website is possible in the following way:

7.5. By default, most web browsers available on the market accept the storage of Cookies. Everyone has the possibility to determine the conditions for using Cookies via the settings of their own web browser. This means, for example, that it is possible to partially restrict (e.g., temporarily) or completely disable the ability to store Cookies – however, in the latter case, this may affect some features of the Online Store (for instance, it may not be possible to proceed through the Order pathway via the Order Form due to the fact that Products will not be retained in the cart at subsequent steps of placing the Order).

7.6. The settings of the web browser regarding Cookies are important from the perspective of consent to the use of Cookies by our Online Store – according to the regulations, such consent may also be expressed through the settings of the web browser. Detailed information on changing Cookies settings and on deleting them independently in the most popular web browsers is available in the help section of the web browser and at the following pages (simply click the relevant link):

a) In Chrome:

b) In Firefox:

c) In Internet Explorer:

d) In Opera:

e) In Safari:

f) In Microsoft Edge:

7.7. The Controller may use Google Analytics and Universal Analytics services in the Online Store, provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). These services help the Controller to keep statistics and analyze traffic in the Online Store. The data collected are processed within these services to generate statistics helpful for the administration of the Online Store and analysis of traffic in the Online Store. These data are aggregate in nature. When using the above services in the Online Store, the Controller collects such data as the sources and mediums of acquiring visitors to the Online Store and the way they behave on the Online Store's website, information about the devices and browsers from which they visit the site, IP and domain, geographic data, as well as demographic data (age, gender) and interests.

7.8. It is possible for an individual to easily block the sharing of information about their activity in the Online Store with Google Analytics – for this purpose, one can, for example, install the browser add-on provided by Google Ireland Ltd., available here:

7.9. Due to the possibility of the Controller using advertising and analytics services provided by Google Ireland Ltd. in the Online Store, the Controller indicates that the full information regarding the rules of processing data of visitors to the Online Store (including information recorded in Cookies) by Google Ireland Ltd. can be found in the privacy policy of Google services, available at the following address:

7.10. The Controller may use the Facebook Pixel service in the Online Store, provided by Meta Platforms Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland). This service helps the Controller measure the effectiveness of advertisements and learn what actions visitors to the Online Store take, as well as display tailored advertisements to these individuals. Detailed information on the operation of the Facebook Pixel can be found at the following web address:

7.11. Managing the functioning of the Facebook Pixel is possible via the advertisement settings in your account at Facebook.com:

8. FINAL PROVISIONS

8.1. The Online Store may contain links to other websites. The Controller encourages that, after moving to other websites, you should read the privacy policies established there. This privacy policy applies only to the Controller’s Online Store.

8.2. The privacy policy in this wording enter into force on 10 August 2025.

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Privacy policy

Purpose of data processing

Legal basis for data processing

Data retention period

Execution of the Sales Agreement or the agreement for the provision of Electronic Services or taking action at the request of the data subject before concluding the aforementioned 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

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

Direct marketing

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 of caring for the interests and good image of the Controller, its Online Store, and striving to sell Products

The Controller may not process data for direct marketing purposes in the event of a valid objection in this regard by the data subject.

Marketing

Article 6(1)(a) of the GDPR (consent) – the data subject has consented to the processing of their personal data for marketing purposes by the Controller

Data is stored until the consent is withdrawn by the data subject for further processing of their data for this purpose.

Expression by the Customer of an opinion on the concluded Sales Agreement

Article 6(1)(a) of the GDPR – the data subject has consented to the processing of their personal data for the purpose of expressing an opinion

Data is stored until the consent is withdrawn by the data subject for further processing of their data for this purpose.

Keeping tax or accounting books

Data is stored for the period required by law obliging the Controller to keep tax books (until the expiry of the tax obligation limitation period, unless tax laws state otherwise) or accounting books (5 years from the beginning of the year following the financial year to which the data relates).

Establishing, pursuing or defending claims that may be raised by the Controller or that may be raised against the Controller

Data is stored for the period of existence of the legitimate interest pursued by the Controller, but no longer than the limitation period of 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 operation

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 of operating and maintaining the Online Store website

Keeping statistics and analyzing traffic in the Online Store