ADSYSTEM STORE PRIVACY POLICY.
This Privacy Policy (hereinafter: the „"Policy"”) provides information about the processing of your personal data in connection with the use of the online store „adsystem.”, operating at the web address: https://www.adsystem.pl/ (hereinafter: „Store”).
Any terms written in capital letters that are not otherwise defined in the Policy shall have the meanings assigned to them in the Terms and Conditions available at: Regulamin.
Personal Data Controller
The Data Controller for your personal data is Adsystem spółka z ograniczoną odpowiedzialnością, with its registered office in Bielany Wrocławskie (address: ul. Atramentowa 11, 55-040 Bielany Wrocławskie), registered in the National Court Register maintained by the District Court for Wrocław-Fabryczna in Wrocław, VI Economic Division of the National Court Register under number KRS: 0000229449, holding the NIP no.: 8942678597, National Business Register (REGON) No.: 93266059700000, with a share capital of PLN 58,500 (fifty-eight thousand five hundred zloty) fully paid (hereinafter: the „Controller”).
Contacting the Controller
In all matters related to the processing of personal data, you can contact the Controller via e-mail, at:office@adsystem.pl.
Data Protection Measures
The Controller employs modern organizational and technical safeguards to ensure the best possible protection of your personal data and guarantees that it processes data in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 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: „GDPR”), the Act of May 10, 2018, on the Protection of Personal Data, and other data protection regulations.
Information on the Processing of Personal Data
Using the Store requires the processing of your personal data. Below, you will find detailed information about the purposes and legal bases for the processing, as well as the processing period and whether providing the data is mandatory or voluntary.
Processing purpose | Personal data processed | Legal basis |
Conclusion and execution of the Agreement for the provision of the Account Service | Name and surname, e-mail address, phone number, data provided by the User on Facebook and Google in the event of the conclusion of an Agreement for the provision of the Account Service through these platforms | Art. 6(1)(h) of the GDPR (processing is necessary for the performance of the Agreement for the provision of the Account Service concluded with the data subject or for taking steps to conclude the Agreement) |
Providing the aforementioned personal data is a condition for concluding and performing the Agreement for the provision of the Account Service (providing the data is voluntary, but failure to provide it will result in the inability to conclude and perform the aforementioned Agreement, including the creation of an Account). The Controller will process the aforementioned personal data until the expiration of claims arising from the Agreement for the provision of the Account Service. | ||
Processing purpose | Personal data processed | Legal basis |
Conclusion and execution of the Sales Agreement | Name and surname, e-mail address, phone number, Residential/business address (street, house number, apartment number, city, postal code, country), Delivery address (if different from the residential/business address), Optionally – company and NIP (if the Buyer is an Entrepreneur or an Entrepreneur with Consumer rights) | Art. 6(1)(h) of the GDPR (processing is necessary for the performance of the Sales Agreement concluded with the data subject or for taking steps to conclude the Agreement) |
Providing the aforementioned personal data is a condition for concluding and performing the Sales Agreement (providing the data is voluntary, but failure to do so will result in the inability to conclude and perform the Sales Agreement). The Controller will process the aforementioned personal data until the expiration of claims arising from the Sales Agreement. | ||
Processing purpose | Personal data processed | Legal basis |
Conclusion and execution of the Newsletter Delivery Agreement | 1) first name, 2) e-mail address | Art. 6(1)(h) of the GDPR (processing is necessary for the performance of the Newsletter Delivery Agreement concluded with the data subject or for taking steps to conclude the Agreement) and Art. 6(1)(f) of the GDPR (The processing is necessary to pursue the Controller's legitimate interest, in this case, informing about news and promotions available in the Store.) |
Providing the aforementioned personal data is voluntary but necessary to receive the Newsletter (the consequence of not providing the data will be the inability to receive the Newsletter). The Controller will process the aforementioned personal data until a valid objection is raised, the processing purpose is achieved, or until the expiration of claims arising from the Newsletter Delivery Agreement (whichever occurs first). | ||
Processing purpose | Personal data processed | Legal basis |
Conducting the complaint procedure | Name and surname, e-mail address, mailing address (in the case of submitting a complaint via traditional mail) | Art. 6(1)(c) GDPR (processing is necessary to fulfill the legal obligation of the Controller, in this case the obligations of: providing a response to the complaint – Article 7a of the Consumer Rights Act; fulfilling the Customer's rights under the provisions concerning the Controller's liability in case of non-compliance of the physical Goods with the Sales Agreement or the digital Product with the relevant Agreement) |
Providing the aforementioned personal data is a condition for receiving a response to the complaint or for fulfilling the Customer's rights under the provisions regarding the Controller's liability in case of non-compliance of the physical Goods with the Sales Agreement or the digital Product with the relevant Agreement (the data provision is voluntary, but the consequence of not providing it will be the inability to receive a response to the complaint or to exercise the aforementioned rights). The Controller will process the aforementioned personal data for the duration of the complaint procedure, and in the case of exercising the aforementioned Customer rights, until the expiration of claims. | ||
Processing purpose | Personal data processed | Legal basis |
Conducting verification procedures and reviewing appeals regarding decisions on the handling of prohibited content | Name/company name, Contact information, including email address | Art. 6(1)(c) GDPR (processing is necessary to fulfill the legal obligation of the Controller, in this case the obligations of: ensuring a mechanism for reporting prohibited content (Article 16 of Regulation 2022/2065 on a Single Market for Digital Services and amending Directive 2000/31/EC (Digital Services Act, hereinafter: the „DSA”), handling complaints (Article 20 of the DSA). |
Providing the aforementioned personal data is a condition for receiving a response to the report or exercising the User's rights under the DSA (providing this data is voluntary, but the consequence of not providing it will be the inability to receive a response to the report or exercise the aforementioned rights). The Controller will process the aforementioned personal data for the duration of the complaint procedure, and in the case of exercising the aforementioned User rights, until the expiration of claims. | ||
Processing purpose | Personal data processed | Legal basis |
Sending e-mail notifications | e-mail address | Art. 6(1)(f) of the GDPR (processing is necessary for the purposes of the legitimate interests pursued by the Controller, in this case, informing Clients about actions related to the execution of Agreements concluded with Clients) |
Providing the aforementioned personal data is voluntary but necessary for receiving information about actions related to the execution of Agreements concluded with Clients (the consequence of not providing this data will be the inability to receive the aforementioned information). The Controller will process the aforementioned personal data until an effective objection is raised or the purpose of processing is achieved (whichever of these events occurs first). | ||
Processing purpose | Personal data processed | Legal basis |
Handling inquiries submitted by Clients | First name, e-mail address, other data included in the message to the Controller | Art. 6(1)(f) of the GDPR (processing is necessary for the purposes of the legitimate interests pursued by the Controller, in this case, to respond to the received inquiry) |
Providing the aforementioned personal data is voluntary but necessary to receive a response to the inquiry (the consequence of not providing this data will be the inability to receive a response). The Controller will process the aforementioned personal data until an effective objection is raised or the purpose of processing is achieved (whichever of these events occurs first). | ||
Processing purpose | Personal data processed | Legal basis |
Sharing Reviews of Goods | e-mail address, optionally – other data included in the Review | Art. 6(1)(f) of the GDPR (processing is necessary for the purposes of the legitimate interests pursued by the Controller, in this case, to make the reviews available for informational and promotional purposes) |
Providing the aforementioned personal data is voluntary but necessary to submit a review (the consequence of not providing this data will be the inability to submit the review). The Controller will process the aforementioned personal data until an effective objection is raised or the purpose of processing is achieved (whichever of these events occurs first). | ||
Processing purpose | Personal data processed | Legal basis |
Informing Customers about the Availability of Previously Unavailable Goods | e-mail address | Art. 6(1)(f) of the GDPR (processing is necessary for the purposes of the legitimate interests pursued by the Controller, in this case, informing customers about the availability of previously unavailable Goods) |
Providing the aforementioned personal data is voluntary but necessary to receive a notification about the availability of previously unavailable goods (the consequence of not providing this data will be the inability to receive such a notification). The Controller will process the aforementioned personal data until an effective objection is raised or the purpose of processing is achieved (whichever of these events occurs first). | ||
Processing purpose | Personal data processed | Legal basis |
Fulfillment of Tax Obligations (including issuing VAT invoices, storing accounting documentation) | name and surname / company, residential address/registered office, Taxpayer Identification Number (NIP) | Art. 6(1)(c) GDPR (processing is necessary for compliance with a legal obligation to which the Controller is subject, in this case, obligations arising from tax law) |
Providing the aforementioned personal data is voluntary but necessary for the Controller to fulfill its tax obligations (the consequence of not providing this data will be the inability for the Controller to meet these obligations). The Controller will process the aforementioned personal data for a period of 5 years from the end of the year in which the deadline for payment of the tax for the previous year expired. | ||
Processing purpose | Personal data processed | Legal basis |
Fulfillment of Obligations Related to Personal Data Protection | Name and surname, contact details provided by you (email address, correspondence address, phone number) | Art. 6(1)(c) GDPR (processing is necessary for compliance with a legal obligation to which the Controller is subject, in this case, obligations arising from personal data protection regulations) |
Providing the aforementioned personal data is voluntary but necessary for the Controller to properly fulfill obligations arising from personal data protection regulations, including exercising the rights granted to you by the GDPR (the consequence of not providing this data will be the inability to properly exercise these rights). The Controller will process the aforementioned personal data until the expiration of the limitation periods for claims related to breaches of personal data protection regulations. | ||
Processing purpose | Personal data processed | Legal basis |
Establishment, Pursuit, or Defense Against Claims | name and surname / company, e-mail address, residential address/registered office, PESEL number (Tax ID), Taxpayer Identification Number (NIP) | Art. 6(1)(f) of the GDPR (processing is necessary for the purposes of the legitimate interests pursued by the Controller, in this case, the establishment, pursuit, or defense of claims that may arise in connection with the performance of Agreements concluded with the Controller). |
Providing the aforementioned personal data is voluntary but necessary for the establishment, pursuit, or defense against claims that may arise in connection with the performance of Agreements concluded with the Controller (the consequence of not providing this data will be the inability for the Controller to undertake such actions). The Controller will process the aforementioned personal data until the expiration of the limitation periods for claims that may arise in connection with the performance of Agreements concluded with the Controller. | ||
Processing purpose | Personal data processed | Legal basis |
Analysis of Your Activity in the Store | date and time of visit, IP address of the device, type of device operating system, approximate location, type of internet browser, time spent in the Store, viewed Goods, visited subpages, and other actions taken within the Store. | Art. 6(1)(f) of the GDPR (processing is necessary for the purposes of the legitimate interests pursued by the Controller, in this case, obtaining information about your activity in the Store). |
Providing the aforementioned personal data is voluntary but necessary for the Controller to obtain information about your activity in the Store (the consequence of not providing this data will be the inability for the Controller to obtain the above information). The Controller will process the aforementioned personal data until a valid objection is made or the processing purpose is achieved, whichever occurs first. | ||
Processing purpose | Personal data processed | Legal basis |
Administration of the Store | IP address, server date and time, information about the internet browser, information about the operating system These data are automatically recorded in server logs each time the Store is used (administering the Store without server logs and automatic recording would not be possible). . | Art. 6(1)(f) of the GDPR (processing is necessary for the purposes of the legitimate interests pursued by the Controller, in this case, ensuring the proper functioning of the Store). |
Providing the aforementioned personal data is voluntary but necessary to ensure the proper functioning of the Store (the consequence of not providing this data will be the inability to ensure the Store's proper operation). The Controller will process the aforementioned personal data until a valid objection is made or the processing purpose is achieved, whichever occurs first. |
Profiling
In order to create your profile for marketing purposes and to direct personalized direct marketing based on your preferences, the Controller will process your personal data in an automated manner, including profiling. However, this will not produce any legal effects on you or similarly significantly impact your situation. The scope of profiled personal data corresponds to the range mentioned above regarding the analysis of your activity in the Store and the data you provide on your Account.
The legal basis for the processing of personal data for the above purpose is Article 6(1)(f) of the GDPR, according to which the Controller may process personal data in order to pursue its legitimate interests, in this case to conduct marketing activities tailored to the recipients' preferences. Providing the above personal data is voluntary but necessary to achieve the above-mentioned purpose (the consequence of not providing this data will be the inability of the Controller to conduct marketing activities tailored to the recipients' preferences).
The Controller will process personal data for profiling purposes until an objection is effectively raised or the processing purpose is fulfilled.
Recipients of Personal Data
The recipients of personal data will include the following external entities cooperating with the Controller:
1. hosting company;
2. logistics operator and courier companies;
3. providers of online payment systems;
4. provider of the platform for publishing and verifying reviews;
5. newsletter service provider;
6. companies providing tools for analyzing activity in the Store and directing direct marketing to its users (e.g., Google Analytics);
7. accounting service provider;
8. legal service provider.
Additionally, personal data may also be transferred to public or private entities if such an obligation arises from generally applicable laws, a final court judgment, or a binding administrative decision.
Transfer of Personal Data to Third Countries
In connection with the Controllers use of services provided by Meta Platforms Ireland Limited and Google LLC, your personal data may be transferred to the following third countries: United Kingdom, Canada, USA, Chile, Brazil, Israel, Saudi Arabia, Qatar, India, China, South Korea, Japan, Singapore, Taiwan (Republic of China), Indonesia, and Australia. The legal bases for the transfer of data to these third countries are:
* For the United Kingdom, Canada, Israel, Japan, and South Korea: European Commission adequacy decisions determining an adequate level of personal data protection in each of these third countries;
* For the USA: Implementing Decision (EU) 2023/1795 of July 10, 2023, under Regulation (EU) 2016/679, determining an adequate level of personal data protection under the EU-US Data Privacy Framework;
* For Chile, Brazil, Saudi Arabia, Qatar, India, China, Singapore, Taiwan (Republic of China), Indonesia, and Australia: Contractual clauses ensuring an adequate level of protection in line with the standard contractual clauses set out in Commission Implementing Decision (EU) 2021/914 of June 4, 2021, regarding the transfer of personal data to third countries under Regulation (EU) 2016/679.
You can obtain a copy of the data transferred to a third country from the Controller.
Rights
In connection with the processing of personal data, you are entitled to the following rights:
1. Right to Information and Access: You have the right to know what personal data the Controller processes concerning you and to receive a copy of that data (the so-called right of access). The first copy of the data is free of charge, but the Controller may charge a fee for subsequent copies;
2. Right to Rectification: If the processed data becomes outdated, incomplete, or otherwise inaccurate, you have the right to request its rectification;
3. In certain situations, you may ask the Controller to delete your personal data, such as when:
1. The data is no longer needed for the purposes the Controller previously informed you about;
2. You have effectively withdrawn your consent to the processing, provided the Controller does not have a legal basis to continue processing;
3. The processing is unlawful;
4. Deletion is required to comply with a legal obligation incumbent upon the Controller;
4. If your personal data is processed by the Controller based on consent or for the execution of an Agreement, you have the right to transfer your data to another controller;
5. If your personal data is being processed based on your consent, you have the right to withdraw that consent at any time (withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal);
6. If you believe that the personal data is inaccurate, the processing is unlawful, or the Controller no longer needs the data, you may request that the Controller refrain from processing the data for a certain period (for example, while verifying its accuracy or pursuing claims) and only store it during that time;
7. You have the right to object to the processing of personal data when the processing is based on the Controller's legitimate interests. If the objection is successful, the Controller will cease processing the personal data for the stated purpose;
8. You have the right to lodge a complaint with the President of the Personal Data Protection Office if you believe that the processing of your personal data violates the provisions of the GDPR.
Cookies
1. The Controller informs you that the Store uses "cookies," which are installed on your end device. These are small text files that can be read by the Controller’s system, as well as by systems belonging to other entities whose services the Controller uses.
2. The Controller uses cookies for the following purposes:
1. Ensuring proper operation of the Store – Cookies enable the efficient functioning of the Store, the use of its features, and smooth navigation between different subpages.
2. Improving Store user experience – Cookies help detect errors on certain subpages and continuously improve them.
3. Creating statistics – Cookies are used to analyze how users interact with the Store. This allows for ongoing improvements and adjustments to the Store’s operations according to user preferences.
4. Conducting marketing activities – Cookies enable the Controller to direct advertisements to users based on their preferences.
3. The Controller may install both persistent and temporary (session) cookies on your device. Session cookies are typically deleted when the browser is closed, whereas closing the browser does not delete persistent cookies.
4. Information about the cookies used by the Controller is displayed in a panel located at the bottom of the Store’s website. Depending on your preference, you can enable or disable cookies in specific categories (except for essential cookies) and change these settings at any time.
5. The data collected via cookies does not allow the Controller to identify you personally.
6. Detailed information about the types of cookies used by the Controller can be found in the panel at the bottom of the Store’s website.
7. Through most commonly used browsers, you can check whether cookies have been installed on your end device, as well as remove installed cookies and block their future installation by the Store. However, disabling or limiting cookies may cause significant difficulties in using the Store, such as the need to log in on every subpage, longer page loading times, and restrictions on using certain functionalities.
Final Provisions
In matters not regulated by this Policy, the generally applicable data protection regulations shall apply.
The Policy is effective from 11.09.2024 r.