Privacy Policy

WHO IS RESPONSIBLE FOR THE PERSONAL DATA ENTRUSTED TO US:

1. Data controllers:

We, Litex Promo Sp. z o.o., with its registered office in Ostrów Wielkopolski, ul. Staroprzygodzka 117, 63-400 Ostrów Wielkopolski, entered in the Register of Entrepreneurs of the National Court Register (KRS) by the District Court in Poznań for Nowe Miasto and Wilda, 9th Commercial Division of the National Court Register, under number 0000378283, Tax Identification Number (NIP) 8971770609, and the Lubawa Capital Group (hereinafter referred to as: ‘Lubawa Group’), i.e. all entities forming part of the capital group, as well as our trusted partners, i.e. entities not forming part of the Lubawa Group but acting as our partners with whom we cooperate on an ongoing basis (hereinafter referred to as: ‘Trusted Partners’). Detailed information regarding the joint controllers is provided below.

WHY WE PROCESS YOUR PERSONAL DATA JOINTLY AND OUR MUTUAL AGREEMENTS

2. Joint arrangements between Data Controllers

In most cases, cooperation between Data Controllers is aimed at providing you with the best possible service when performing contracts and fulfilling orders, better tailoring offers to your needs, as well as carrying out various studies and activities aimed at managing resources more efficiently and adapting them to the needs of our business partners.

As the Lubawa Group and Trusted Partners operate on a joint controller basis, in accordance with Article 26 of the GDPR, we have entered into a relevant agreement. Each Data Controller exercises due diligence to ensure the security of your data processing, and you may contact any of them with any queries. In particular, we have agreed that:

1. The Data Controller collecting personal data is responsible for fulfilling the information obligation towards you in accordance with Articles 13 and 14 of the GDPR;
2. Each Data Controller is responsible for enabling you to exercise the rights set out in this document, via the contact point we have established (details below). Notwithstanding the above, you may exercise your rights by submitting your requests, applications or enquiries to any of the Controllers. In such a case, the Controller to whom you address your request will forward it to the other Controllers for processing, and will then provide you with a response in accordance with the rules and within the time limits set out in Article 12 of the GDPR;
3. The Controller receiving your personal data is responsible for the accuracy of the data collected;
4. The data controller, Litex Service sp. z o.o., with its registered office in Ostrów Wielkopolski, also ensures the external security of its IT systems against unauthorised access and maintains an internal organisation that provides the best possible protection.

HOW YOU CAN CONTACT US REGARDING OUR PROCESSING OF PERSONAL DATA

3. Point of contact

Together, we have decided to establish a single point of contact which you may contact regarding matters relating to the protection of personal data and the exercise of your rights in connection with data processing. Please note that the Data Controller has appointed a Data Protection Officer, whom you may contact as indicated below:

• postal address (traditional post): Litex Service Sp. z o.o., ul. Staroprzygodzka 117, 63-400 Ostrów Wielkopolski;
• email: [email protected]

TYPES OF PERSONAL DATA WE PROCESS:

4. Types of data processed:

The way in which you interact with us determines what types of your personal data we will process:

If you use our website to order goods or services, or to make an enquiry, we will need data from you that is necessary to fulfil your request, in particular: to finalise an order, to provide a service or fulfil an order, and to enable you to use the electronic services available on our website.

If you consent to the use of cookies on the Controller’s website, the Controller will also have access to your personal data in connection with your use of the services provided through the online shop:

Google Ads Enhanced Conversion:

• scope of data: email address, telephone number, first name, surname, address, transaction ID;
• data is encrypted before being sent to Google

You can find out more about how Google processes personal data on the website https://policies.google.com/privacy?hl=en

FOR WHAT PURPOSES AND ON WHAT LEGAL BASIS DO WE PROCESS YOUR PERSONAL DATA:

5. Purposes and legal bases for processing

We have jointly agreed on the purposes of processing your data

PLACING AN ORDER

The personal data we collect in connection with an order placed will be processed, in particular, for the following purpose and on the following legal basis:

• Article 6(1)(b) of the GDPR for the purpose of concluding and fulfilling the order, as well as for the purpose of fulfilling other obligations arising from the contract;
• Article 6(1)(c) of the GDPR: your data will be processed to fulfil the legal obligation incumbent on the Controller relating to the issuance and storage of accounting documents, including invoices for services provided or commissioned by the Controller, the exercise of after-sales rights to which you or the Controller are entitled, and the fulfilment of other legal obligations imposed on the Controller by mandatory provisions of law;
• Article 6(1)(f) of the GDPR: personal data may also be processed for the purpose of defending against and in connection with the pursuit of claims;

CONTACT BY TELEPHONE OR E-MAIL

Personal data that we collect when you use the telephone numbers for our helpline or our email addresses will be processed on the basis of and for the following purposes:

• Article 6(1)(b) of the GDPR: to handle your enquiry and fulfil your request;
• Article 6(1)(c) of the GDPR: may be processed to fulfil a legal obligation incumbent on the Data Controller under applicable data protection legislation (e.g. responding to requests from individuals – exercising rights under the GDPR), in relation to the proper management and operation of the website; – handling complaints regarding posted reviews and fulfilling other obligations arising from mandatory legal provisions;
• Article 6(1)(f) of the GDPR: personal data may also be processed for the purposes of defending against and in connection with the pursuit of legal claims.

MARKETING INFORMATION

AS PART OF THE WEBSITE’S OPERATION, YOU MAY GIVE YOUR CONSENT EXCLUSIVELY TO THE CONTROLLER – Litex Promo Sp. z o.o., with its registered office in Ostrów Wielkopolski, ul. Staroprzygodzka 117, Tax Identification Number (NIP) 8971770609 – to the processing of your data for the purpose of sending marketing information, and such data will be processed on the basis of and for the purpose of:

• Article 6(1)(a) of the GDPR – on the basis of the consent given for the sending of marketing information by Litex Promo Sp. z o.o., ul. Staroprzygodzka 117, 63-400 Ostrów Wielkopolski, NIP 8971770609, via the email address or mobile phone number provided.
• Article 6(1)(c) of the GDPR: personal data may be processed to fulfil a legal obligation to which the Data Controller is subject under applicable data protection legislation (e.g. responding to requests from individuals – exercising their rights under the GDPR), in relation to the proper management and operation of the website and the fulfilment of other obligations arising from mandatory legal provisions;
• Article 6(1)(f) may also be processed for the purpose of defending against and in connection with the pursuit of legal claims;

DATA COLLECTED IN CONNECTION WITH THE OPERATION OF THE WEBSITE – DATA COLLECTED THROUGH COOKIES

• Article 6(1)(a) of the GDPR – on the basis of consent given to the use of cookies for analytical and marketing purposes in connection with the Controller’s operation of the website.

6. Recipients of the data

Access to your data is restricted to authorised employees and associates of the Controllers, as well as other entities that support or may support the Controllers’ day-to-day operations. Accordingly, your personal data may be disclosed, in particular, to: hosting service providers and service providers of specific tools/applications/programmes, in particular Google Ads, Google Analytics 4, Google Tag Manager and Microsoft Clarity used on the Controller’s website, as well as entities involved in the implementation of marketing campaigns; to carriers/suppliers of ordered Products; to entities that process electronic payments or card payments (PAYNOW/PayU/PayPal); entities dealing with financial settlements, the protection of property and persons, law firms, advisory and consultancy firms, and archiving services, IT equipment and software maintenance services in which the data is stored, and entities authorised under mandatory provisions of law.

RIGHTS

7. Rights of data subjects. You have the right to request from the Controller:

1. access to your personal data,
2. the right to rectification,
3. the right to erasure,
4. the right to restrict processing,
5. the right to data portability,
6. if the Controller processes your personal data on the basis of consent, you have the right to withdraw your consent at any time; this does not affect the lawfulness of processing carried out prior to the withdrawal of consent.
7. notwithstanding the provisions set out above, you have the right to object to the processing of personal data where such processing is not based on your consent, a contract or a legal provision, and the sole basis for this is the Controller’s legitimate interest. If you lodge an objection, following consideration of your request, the Controller will no longer be able to process the personal data covered by the objection, unless we demonstrate that there are compelling legitimate grounds for the processing which, under the law, take precedence over your interests, rights and freedoms, or there are grounds for establishing, exercising or defending legal claims;

To exercise the above rights, please contact the point of contact indicated in point 3) above. However, with regard to cookies set via Google Ads extended conversion tracking, you may withdraw your consent in the manner specified in the Service Provider’s privacy policy at https://policies.google.com/privacy?hl=en

8. you have the right to lodge a complaint with the supervisory authority, i.e. the President of the Office for Personal Data Protection, if you believe that the Controller’s processing of personal data is in breach of the law.

HOW LONG DO WE PROCESS YOUR PERSONAL DATA

8. Data retention period

The retention period for your personal data depends on the legal basis and purpose for which it is processed, as follows:

• Personal data processed in connection with the fulfilment of an order will be processed for the duration of the Contract, and subsequently until any mutual claims have expired, and for the period required by mandatory legal provisions, in particular those relating to tax and accounting law.
• Where we process your data on the basis of our legitimate interest, this will continue until you lodge an objection, as set out in point 7(g) above.
• DATA RETENTION PERIOD FOR DATA PROCESSING BASED ON CONSENT GIVEN SOLELY TO THE CONTROLLER – Litex Promo Sp. z o.o., with its registered office in Ostrów Wielkopolski, ul. Staroprzygodzka 117, Tax Identification Number (NIP) 8971770609, for the processing of your data for the purpose of sending marketing information: where the Controller processes your data on the basis of your consent (consent to receive marketing information) until such consent is withdrawn, which has been taken into account in accordance with your request, unless there is a need for further processing of this data due to legal provisions that will oblige us to process it for a longer period; alternatively, we may process your data for a longer period in the event of any claims being made against us, for the duration of the limitation period specified by applicable law.

In all cases, the longer retention period for personal data shall apply.

In the case of cookies for extended conversion tracking in GOOGLE ADS: the retention period shall be a maximum of 13 months or until you withdraw your consent from the Controller or the Service Provider.

PROFILING

9. Profiling

The controller does not process personal data by automated means, including profiling.

No decisions are made in relation to you that could produce legal effects or otherwise significantly affect you as a result of automated data processing, including through the profiling of your behaviour.

Should your data be subject to such automated data processing, this may only take place after your consent has been obtained.

At the same time, the Controllers point out that, within the tools they use to operate the website, profiling may only take place to the extent of your consent to the use of cookies by us. The results of Google Ads extended conversion tracking may influence the automatic adjustment of Google Ads bids (so-called ‘smart bidding’); this does not have any legal consequences for you.

TRANSFER OF DATA OUTSIDE THE EUROPEAN GEOGRAPHICAL AREA

10. Transfer of data outside the European Economic Area

The Controller processes your data within the European Economic Area (hereinafter: EEA); however, data may be transferred to countries outside the EEA in connection with the tools used by the Controller to process your personal data. In such cases, data is transferred between the Controller and a third party cooperating with them in the role of a service provider for a specific tool/application/programme, e.g. Google (for more information on the processing of personal data, please visit https://policies.google.com/privacy?hl=en) or Microsoft (further information can be found at https://learn.microsoft.com/en-us/clarity/faq). Data may also be transferred at your request.

However, the Controller ensures that the transfer of personal data takes place only to the extent necessary and in compliance with the requirements set out in Chapter V of the GDPR. For further information, please send an enquiry to our Data Protection Officer – contact details: [email protected].

THE NEED TO PROVIDE DATA

11. Information on the voluntary nature of providing data

The provision of personal data is voluntary; however, a refusal to provide such data will prevent the performance of the contract or may result in the refusal to fulfil the order/contract. The provision of data for the purpose of sending marketing information is voluntary.

LUBAWA CAPITAL GROUP

TRUSTED PARTNERS

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