PRIVACY POLICY

OF THE ONLINE STORE ETHNE.EU

TABLE OF CONTENTS:

1. GENERAL PROVISIONS
2. BASIS 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 PERSON WHOSE DATA IS BEING PROCESSED
7. COOKIES IN THE ONLINE STORE AND ANALYTICS
8. FINAL PROVISIONS

1. GENERAL PROVISIONS

1.1 This Privacy Policy of the Online Store is of an informative nature, which means that it is not a source of obligations for Service Recipients or Customers of the Online Store. The privacy policy primarily contains rules regarding the processing of personal data by the Administrator in the Online Store, including the grounds, purposes and scope of personal data processing and the rights of persons whose data are processed, as well as information on the use of cookies and analytical tools in the Online Store.

1.2 The Administrator of personal data collected through the Online Store is ETHNE sp. z o.o. (limited liability company), entered into the Register of Entrepreneurs of the National Court Register under KRS number: 0000971781, having: a place of business address and an address for service at Hoża 86/410, 00-682 Warsaw, Poland, VAT number: PL7011087899, REGON: 522029577,
e-mail address: contact@ethne.eu, phone number: +48 22 100 60 88 – hereinafter referred to as “the Administrator”, who is also the Service Provider of the Online Store and Seller.

1.3. Personal data in the Online Store are processed by the Administrator in accordance with applicable law, in particular with the Regulation of the European Parliament and of the Council (EU) 2016/679 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 “GDPR” or “GDPR Regulation”. Official text of GDPR: http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32016R0679

1.4. Using the Online Store, including making purchases, is voluntary. Similarly, providing personal data by a User or Customer using the Online Store is voluntary, subject to two exceptions: (1) concluding agreements with the Administrator – failure to provide personal data in cases and to the extent indicated on the Online Store’s website and in the Online Store’s Regulations and this privacy policy that are necessary for concluding and performing a Sales Agreement or an Electronic Service Agreement with the Administrator results in the inability to conclude such an agreement. Providing personal data is a contractual requirement in such a case and if a person whose data it concerns wants to conclude a given agreement with the Administrator, they are obliged to provide the required data. The scope of data required for concluding an agreement is indicated each time on the Online Store’s website and in the Online Store’s Regulations; (2) statutory obligations of the Administrator – providing personal data is a statutory requirement resulting from generally applicable legal provisions imposing on the Administrator an obligation to process personal data (e.g. processing data for tax or accounting purposes) and failure to provide them will prevent the Administrator from fulfilling these obligations.

1.5. The Administrator takes special care to protect the interests of persons whose personal data it processes, and in particular is responsible and ensures that the data collected by it are: (1) processed lawfully; (2) collected for specified, lawful purposes and not further processed in a manner incompatible with those purposes; (3) factually correct and adequate in relation to the purposes for which they are processed; (4) stored in a form that allows identification of the persons to whom they relate for no longer than is necessary to achieve the purpose of processing; and (5) processed in a manner ensuring appropriate security of personal data, including protection against unauthorized or unlawful processing and accidental loss, destruction or damage, using appropriate technical or organizational measures.

1.6. Taking into account the nature, scope, context and purposes of processing as well as the risk of violating the rights or freedoms of natural persons of varying likelihood and severity of threat, the Administrator implements appropriate technical and organizational measures to ensure that processing is carried out in accordance with this Regulation and to be able to demonstrate this. These measures are reviewed and updated as necessary. The Administrator uses technical measures to prevent unauthorized acquisition and modification by unauthorized persons of personal data transmitted electronically.

1.7. All words, phrases and acronyms appearing in this privacy policy and beginning with a capital letter (e.g. Seller, Online Store, Electronic Service) shall be understood in accordance with their definition contained in the Terms and Conditions of the Online Store available on the Online Store’s website.

2. BASIS FOR DATA PROCESSING

2.1. The Administrator is authorized to process personal data in cases where – and to the extent that – at least one of the following conditions is met: (1) the person whose data it concerns has given 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 person whose data it concerns is a party or for taking action at the request of the person whose data it concerns prior to entering into a contract; (3) processing is necessary for compliance with a legal obligation to which the Administrator is subject; or (4) processing is necessary for purposes arising from legitimate interests pursued by the Administrator or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the person whose data it concerns requiring protection of personal data, in particular where the person whose data it concerns is a child.

2.2. Processing of personal data by the Administrator requires each time at least one of the grounds indicated in point 2.1 of the privacy policy to occur. The specific grounds for processing personal data of Service Recipients and Customers of the Online Store by the Administrator are indicated in the next point of the privacy policy – with respect to a given purpose of processing personal data by the Administrator.

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

3.1. Each time the purpose, basis and period as well as the recipients of personal data processed by the Administrator result from the actions taken by a given Service Recipient or Customer in the Online Store or by the Administrator. For example, if a Customer decides to make purchases in the Online Store and chooses personal collection of the purchased Product instead of courier delivery, his or her personal data will be processed for the purpose of performing the concluded Sales Agreement, but will no longer be made available to the carrier carrying out shipments at the request of the Administrator.

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

Processing purpose	Legal basis for data processing	Data retention period
Performance of a Sales Agreement or an Electronic Service Agreement or taking action at the request of the person whose data it concerns prior to entering into the above-mentioned agreements	Article 6(1)(b) of the GDPR (performance of a contract) – processing is necessary for the performance of a contract to which the person whose data it concerns is a party or for taking action at the request of the person whose data it concerns prior to entering into a contract	The data is stored for the period necessary for the performance, termination or expiry in another way of the concluded Sales Agreement or Electronic Service Agreement.
Direct marketing	Article 6(1)(f) of the GDPR (legitimate interest of the administrator) – processing is necessary for purposes arising from legitimate interests pursued by the Administrator – consisting in taking care of the interests and good image of the Administrator, his Online Store and striving to sell Products	The data is stored for the period of existence of a legitimate interest pursued by the Administrator, but not longer than for the limitation period for claims of the Administrator against the person whose data it concerns arising from business activity conducted by the Administrator. The limitation period is determined by law, in particular by the Civil Code (the basic limitation period for claims related to business activity is three years and two years for a Sales Agreement). The Administrator cannot process data for direct marketing purposes if an effective objection has been expressed in this respect by the person whose data it concerns.
Marketing	Article 6(1)(a) of the GDPR (consent) – the person whose data it concerns has given consent to the processing of their personal data for marketing purposes by the Administrator	The data is stored until the person whose data it concerns withdraws their consent 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 person whose data it concerns has given consent to the processing of their personal data for the purpose of expressing an opinion	Data is stored until the person whose data it concerns withdraws their consent 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 January 17, 2017 (Journal of Laws of 2017, item 201) or Article 74(2) of the Accounting Act of January 30, 2018 (Journal of Laws of 2018, item 395) – processing is necessary to fulfill a legal obligation incumbent on the Administrator;	The data is stored for the period required by law requiring the Administrator to keep tax books (until the expiry of the limitation period for a tax obligation, unless tax laws provide otherwise) or accounting books (5 years from the beginning of the year following the financial year to which the data relates).
Establishment, investigation or defense of claims that may be raised by the Administrator or that may be raised against the Administrator	Article 6(1)(f) of the GDPR (legitimate interest of the administrator) – processing is necessary for purposes arising from legitimate interests pursued by the Administrator – consisting in establishing, investigating or defending claims that may be raised by the Administrator or that may be raised against the Administrator	The data is stored for the period of existence of a legitimate interest pursued by the Administrator, but not longer than for the limitation period for claims that may be raised against the Administrator (the basic limitation period for claims against the Administrator is six years).
Using the Online Store website and ensuring its proper operation	Article 6(1)(f) of the GDPR (legitimate interest of the administrator) – processing is necessary for purposes arising from legitimate interests pursued by the Administrator – consisting in running and maintaining the Online Store website	The data is stored for the period of existence of a legitimate interest pursued by the Administrator, but not longer than for the limitation period for claims of the Administrator against the person whose data it concerns, resulting from the business activity conducted by the Administrator. The limitation period is determined by law, in particular by the Civil Code (the basic limitation period for claims related to business activity is three years, and for a sales contract two years).
Conducting statistics and analyzing traffic on the Online Store	Article 6(1)(f) of the GDPR (legitimate interest of the administrator) – processing is necessary for purposes arising from legitimate interests pursued by the Administrator – consisting in conducting statistics and analyzing traffic on the Online Store in order to improve its functioning and increase sales of Products	The data is stored for the period of existence of a legitimate interest pursued by the Administrator, but not longer than for the limitation period for claims of the Administrator against the person whose data it concerns, resulting from the business activity conducted by the Administrator. The limitation period is determined by law, in particular by the Civil Code (the basic limitation period for claims related to business activity is three years, and for a sales contract two years).

4. DATA RECIPIENTS IN THE ONLINE STORE

4.1. For the proper functioning of the Online Store, including for the performance of Sales Agreements concluded, it is necessary for the Administrator to use the services of external entities (such as software provider, courier or payment service provider). The Administrator uses only the services of such processing entities that provide sufficient guarantees for the implementation of appropriate technical and organizational measures so that the processing meets the requirements of the GDPR and protects the rights of persons whose data it concerns.

4.2. Data transfer by the Administrator does not occur in every case and not to all recipients or categories of recipients indicated in the privacy policy – the Administrator transfers data only when it is necessary to achieve a given purpose of personal data processing and only to the extent necessary to achieve it. For example, if a Customer uses personal pickup, their data will not be transferred to a carrier cooperating with the Administrator.

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 / freight forwarders / courier brokers / entities servicing warehouse and/or shipping process – in case of a Customer who uses postal or courier delivery method in the Online Store, the Administrator provides collected personal data of the Customer to a selected carrier, freight forwarder or intermediary carrying out shipments on behalf of the Administrator, and if shipment takes place from an external warehouse – to an entity servicing warehouse and/or shipping process – to the extent necessary to deliver Product to Customer.

4.3.2. entities processing electronic payments or card payments – in the case of a Customer who uses electronic payment or card payment method in the Online Store, the Administrator provides the collected personal data of the Customer to the selected entity servicing the above payments in the Online Store at the request of the Administrator to the extent necessary to service the payment made by the Customer.

4.3.3. credit providers / lessors – in the case of a Customer who uses a payment method in an installment system or leasing payment method in the Online Store, the Administrator provides the collected personal data of the Customer to the selected creditor or lessor servicing the above payments in the Online Store at the request of the Administrator to the extent necessary to service the payment made by the Customer.

4.3.4. suppliers of opinion survey systems – in case of a Customer who has agreed to express an opinion on a Sales Agreement concluded, the Administrator provides collected personal data of the Customer to a selected entity providing opinion survey systems for Sales Agreements concluded in the Online Store at the request of the Administrator to an extent necessary for expressing an opinion by a Customer using opinion survey systems.

4.3.5. suppliers of services supplying Administrator with technical, IT and organizational solutions enabling Administrator to conduct business activity, including Online Store and Electronic Services provided through it (in particular suppliers of computer software for conducting Online Store, e-mail and hosting providers and software suppliers for managing company and providing technical support to Administrator) – Administrator provides collected personal data of Customers to selected supplier acting on its behalf only in case and to an extent necessary for realization of given services.

4.3.6. providers of accounting, legal and advisory services providing accounting, legal or advisory support to the Administrator (in particular accounting office, law firm or debt collection company) – the Administrator provides personal data collected from the Customer to a selected provider acting on his behalf only in case and to the extent necessary to achieve a given purpose of data processing in accordance with this privacy policy.

4.3.7. providers of social media plugins, scripts and other similar tools placed on the Internet Store’s website enabling the browser of a person visiting the Internet Store’s website to download content from providers of such plugins (e.g. logging in using login data for a social media service) and for this purpose transferring personal data of a person visiting, including:

4.3.7.1. Meta Platforms Ireland Ltd. – The Administrator uses social media plugins from Facebook on the Internet Store’s website (e.g. Like button!, Share or login using Facebook login data) and therefore collects and provides personal data of the Service Recipient using the Internet Store’s website to Meta Platforms Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland) within the scope and in accordance with privacy policies available here: https://www.facebook.com/about/privacy/ (this data includes information about activities on the Internet Store’s website – including information about devices, visited websites, purchases, displayed advertisements and how services are used – regardless of whether the Service Recipient has a Facebook account and whether he is logged in to Facebook).

5. PROFILING IN THE ONLINE STORE

5.1. The GDPR imposes on the Administrator the obligation to inform about automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR, and – at least in these cases – significant information about the rules for making such decisions, as well as about the meaning and expected consequences of such processing for the person whose data it concerns. Bearing this in mind, the Administrator provides information on possible profiling in this section of the privacy policy.

5.2. The Administrator may use profiling for direct marketing purposes in the Online Store, but decisions made on its basis by the Administrator do not concern the conclusion or refusal to conclude a Sales Agreement or the possibility of using Electronic Services in the Online Store. The effect of using profiling in the Online Store may be, for example, granting a discount to a given person, sending them a discount code, reminding them of unfinished purchases, sending them a proposal for a Product that may correspond to the interests or preferences of a given person or proposing better conditions compared to the standard offer of the Online Store. Despite profiling, a given person makes a free decision whether they want to use the discount received in this way or better conditions and make a purchase in the Online Store.

5.3. Profiling in the Online Store consists of an automatic analysis or forecast of a person’s behavior on the Online Store website e.g. by adding a specific Product to their basket, browsing a specific Product page on the Online Store website or by analyzing their previous purchase history on the Online Store website. A condition for such profiling is that the Administrator has personal data of a given person so that they can then send them e.g. a discount code .

5.4. The person whose data it concerns has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them.

6. RIGHTS OF THE PERSON WHOSE DATA IT CONCERNS

6.1. Right of access, rectification, restriction, erasure or portability – the person whose data it concerns has the right to request from the Administrator access to their personal data, their 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. Detailed conditions for exercising the above rights are set out in Articles 15-21 of the GDPR.

6.2. Right to withdraw consent at any time – the person whose data is processed by the Administrator on the basis of consent given (on the basis of 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 consent before its withdrawal.

6.3. Right to lodge a complaint with a supervisory authority – the person whose data is processed by the Administrator has the right to lodge a complaint with a supervisory authority in accordance with the provisions of the GDPR and Polish law, in particular the Act on Personal Data Protection. The supervisory authority in Poland is the President of the Office for Personal Data Protection.

6.4. Right to object – the person whose data it concerns has the right to object at any time – for reasons related to their particular situation – to the processing of their personal data based on Article 6(1)(e) (public interest or public task) or (f) (legitimate interests of the controller), including profiling based on these provisions. In such a case, the Administrator may no longer process this personal data unless he demonstrates compelling legitimate grounds for processing that override the interests, rights and freedoms of the person whose data it concerns or grounds for establishing, pursuing or defending claims.

6.5. Right to object to direct marketing – if personal data is processed for direct marketing purposes, the person whose data it concerns has the right to object at any time to the processing of their personal data for such marketing purposes, 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 privacy policy, you can contact the Administrator by sending an appropriate message in writing or by e-mail to the Administrator’s address indicated at the beginning of this privacy policy or by using the contact form available on the Online Store website.

7. COOKIES IN THE ONLINE STORE AND ANALYTICS

7.1. Cookies are small text information in the form of text files sent by a server and saved on the side of a person visiting the Online Store website (e.g. on a hard drive of a computer, laptop or on a memory card of a smartphone – depending on which device is used by a visitor of our Online Store). Detailed information about cookies and their history can be found e.g. here: https://en.wikipedia.org/wiki/HTTP_cookie.

7.2. Cookies that may be sent by the Online Store website can be divided into different types according to the following criteria:

Due to their supplier:

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

2) belonging to third parties (other than the Administrator)

Due to their storage period on the device of a person visiting the Online Store website:

1) session (stored until logging out of the Online Store website or turning off the web browser) and

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

Due to their purpose:

1) necessary (enabling the proper functioning of the Online Store website),

2) functional/preference (enabling the adaptation of the Online Store website to the preferences of a person visiting the website),

3) analytical and performance (collecting information about how the Online Store website is used),

4) marketing, advertising and social media (collecting information about a person visiting the Online Store website in order to display personalized ads and conduct other marketing activities, including on websites other than the Online Store website, such as social media portals).

7.3. The Administrator may process data contained in Cookies during visits to the Online Store website for specific purposes:

The purposes of using Cookies in the Administrator’s Online Store are:	identification of Customers as logged in to the Online Store and showing that they are logged in (necessary Cookies)
	remembering Products added to the cart in order to place an Order (necessary Cookies)
	remembering data from Order Forms, surveys or login data for the Online Store (necessary and/or functional/preference Cookies)
	adapting the content of the Online Store website to the individual preferences of Customers (e.g. regarding colors, font size, page layout) and optimizing the use of the Online Store website (functional/preference Cookies)
	conducting anonymous statistics showing how the Online Store website is used (statistical Cookies)
	remarketing, i.e. researching the behavioral characteristics of visitors to the Online Store through anonymous analysis of their actions (e.g. repeated visits to specific pages, keywords, etc.) in order to create their profile and provide them with ads tailored to their predicted interests, even when they visit other websites on Google Ireland Ltd.’s advertising network and Facebook’s Meta Platforms Ireland Ltd. (marketing Cookies).

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

In Chrome:

(1) click on the padlock icon on the left side of the address bar, (2) go to the “Cookies” tab.

In Firefox:

(1) click on the shield icon on the left side of the address bar, (2) go to the “Allowed” or “Blocked” tab, (3) click on the “Cookies tracking between websites”, “Elements tracking social media” or “Content with tracking elements” field.

In Internet Explorer:

(1) click on the “Tools” menu, (2) go to the “Internet Options” tab, (3) go to the “General” tab, (4) go to the “Settings” tab, (5) click on the “Display files” field.

In Opera:

(1) click on the padlock icon on the left side of the address bar, (2) go to the “Cookies” tab.

In Safari:

(1) click on the “Preferences” menu, (2) go to the “Privacy” tab, (3) click on the “Manage website data” field.

Regardless of the browser used, it is possible to use tools available e.g. on websites such as: https://www.cookiemetrix.com/ or https://www.cookie-checker.com/

7.5. By default, most web browsers available on the market accept Cookies. Everyone has the possibility to determine the conditions for using Cookies using their own web browser settings. This means that it is possible to partially limit (e.g. temporarily) or completely disable the possibility of saving Cookies – in this case, however, it may affect some functionalities of the Online Store (for example, it may be impossible to go through an Order path through an Order Form due to not remembering Products in a cart during subsequent steps of placing an Order).

7.6. Internet browser settings regarding Cookies are important from the point of view of consent to use Cookies by our Online Store – according to the regulations, such consent can also be expressed by Internet browser settings. Detailed information on changing settings regarding Cookies and their independent removal in the most popular Internet browsers is available in the help section of your Internet browser and on the following pages (just click on a given link):

– in Chrome: https://support.google.com/chrome/answer/95647?hl=en

– in Firefox: https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop

– in Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies

– in Opera: https://help.opera.com/en/latest/web-preferences/#cookies

– in Safari: https://support.apple.com/guide/safari/sfri11471/mac

– in Microsoft Edge: http://windows.microsoft.com/en-us/windows-10/edge-privacy-faq

7.7. The Administrator may use Google Analytics services in the Online Store, Universal Analytics provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). These services help the Administrator to keep statistics and analyze traffic in the Online Store. The collected data is processed within these services to generate statistics helpful in administering the Online Store and analyzing traffic in the Online Store. This data is of an aggregate nature. By using these services in the Online Store, the Administrator collects data such as sources and media of acquisition of visitors to the Online Store and their behavior on the Online Store website, information about devices and browsers from which they visit the website, IP and domain, geographic data as well as demographic data (age, gender) and interests.

7.8. It is possible for a given person to easily block sharing information about their activity on the Online Store website with Google Analytics – for this purpose, for example, an add-on to a browser provided by Google Ireland Ltd. can be installed here: https://tools.google.com/dlpage/gaoptout?hl=en.

7.9. In connection with the possibility for the Administrator to use advertising and analytical services provided by Google Ireland Ltd. in the Online Store, the Administrator indicates that full information on the rules for processing data of persons visiting the Online Store (including information stored in Cookies) by Google Ireland Ltd. can be found in the privacy policy of Google services available at: https://policies.google.com/technologies/partner-sites.

7.10. The Administrator may use 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 Administrator measure the effectiveness of advertising and learn about what actions visitors to the Online Store take, as well as display personalized ads to them. Detailed information on how Facebook Pixel works can be found at: https://www.facebook.com/business/help/742478679120153?helpref=page_content.

7.11. Management of Facebook Pixel operation is possible through advertising settings in your account on Facebook.com: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen.

8. FINAL PROVISIONS

8.1 The Online Store may contain links to other websites. The Administrator encourages you to read the privacy policy established there after going to other websites. This privacy policy applies only to the Administrator’s Online Store.

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