1. This Privacy Policy defines the rules for processing personal data collected through the online store dym.pl (hereinafter referred to as the "Online Store").
2. The owner of the Store and the Data Controller is PROMOTORZY TRADING SP. Z O.O. based in Warsaw (03-310), Św. Jacka Odrowąża 15, registered in the National Court Register of Entrepreneurs maintained by the District Court for the Capital City of Warsaw in Warsaw, XIII Commercial Division of the National Court Register under the number KRS 0000422037, NIP: 524-27-51-528, Regon: 146139035, hereinafter referred to as PROMOTORZY TRADING SP. Z O.O.
3. Personal data collected by PROMOTORZY TRADING SP. Z O.O. through the Online Store are processed in accordance with the Regulation (EU) 2016/679 of the European Parliament and the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), also known as GDPR.
4. PROMOTORZY TRADING SP. Z O.O. takes particular care to respect the privacy of customers visiting the Online Store.
1. PROMOTORZY TRADING SP. Z O.O. collects information regarding natural persons who perform legal actions not directly related to their business activity, natural persons running their own business or professional activity, as well as natural persons representing legal entities or organizational units not being legal entities, to whom the law grants legal capacity, hereinafter referred to collectively as Customers.
2. Personal data of Customers are collected in the case of:
a) Account registration in the Online Store, for the purpose of creating and managing an individual account. Legal basis: necessity to perform the contract for the provision of the Account service (Article 6(1)(b) GDPR);
b) Placing an order in the Online Store, for the purpose of performing the sales contract. Legal basis: necessity to perform the sales contract (Article 6(1)(b) GDPR);
c) Subscribing to the newsletter, for the purpose of performing the contract for the provision of the electronic service. Legal basis: consent of the data subject for the performance of the Newsletter service contract (Article 6(1)(a) GDPR);
d) Using the contact form service in the Online Store, for the purpose of performing the electronic service contract. Legal basis: necessity to perform the contact form service contract (Article 6(1)(b) GDPR).
3. In the case of account registration in the Online Store, the Customer provides:
a) Email address;
b) Full name;
c) Phone number.
4. During account registration, the Customer sets an individual password for their account. The Customer can change the password later, as described in §6.
5. When placing an order in the Online Store, the Customer provides the following data:
a) Email address;
b) Address details:
a. postal code and city;
b. street with house/apartment number;
c) Full name;
d) Phone number.
6. For Entrepreneurs, the above data is additionally supplemented with:
a) The name of the Entrepreneur;
b) NIP number.
7. When subscribing to the newsletter, the Customer provides only their email address.
8. When using the contact form service, the Customer provides the following data:
a) Email address;
b) First name.
9. While using the Online Store's website, additional information may be collected, in particular: IP address assigned to the Customer's computer or external IP address of the Internet service provider, domain name, browser type, access time, and type of operating system.
10. Navigation data may also be collected, including information about the links and references that the Customer chooses to click on or other actions performed in the Online Store. Legal basis: legitimate interest (Article 6(1)(f) GDPR), aimed at facilitating the use of electronic services and improving their functionality.
11. In order to establish, pursue, and enforce claims, some personal data provided by the Customer while using the functionalities of the Online Store, such as name, surname, and data related to the use of services, may be processed. Legal basis: legitimate interest (Article 6(1)(f) GDPR), aimed at establishing, pursuing, and enforcing claims, as well as defending against claims in court and before other public authorities.
12. PROMOTORZY TRADING SP. Z O.O. processes personal data including: name, surname, email address, as well as answers to prepared questions in satisfaction surveys and forms used for satisfaction testing. Participation in such actions is voluntary. If the Customer does not agree to participate, they can inform PROMOTORZY TRADING SP. Z O.O. at the address provided in §7, and PROMOTORZY TRADING SP. Z O.O. will block the relevant data. Legal basis: legitimate interest (Article 6(1)(f) GDPR), aimed at improving the functionality of services provided electronically and assessing satisfaction with the services provided.
13. Providing personal data to PROMOTORZY TRADING SP. Z O.O. is voluntary, in connection with the concluded sales agreements or the provision of services through the Online Store's website. However, failure to provide certain data in the registration forms will prevent the registration and creation of the Customer's Account, while placing an order without registering the Customer's Account will prevent the order from being placed and fulfilled.
1. The Customer’s personal data is shared with service providers that PROMOTORZY TRADING SP. Z O.O. uses in the operation of the Online Store. Depending on the contractual agreements and circumstances, service providers either follow the instructions of PROMOTORZY TRADING SP. Z O.O. regarding the purposes and methods of processing this data (processors) or determine the purposes and methods of processing on their own (controllers).
a) Processors: PROMOTORZY TRADING SP. Z O.O. uses service providers who process personal data only on the instruction of PROMOTORZY TRADING SP. Z O.O. These include, among others, hosting providers, accounting services, marketing systems, traffic analysis systems for the Online Store, and systems for analyzing the effectiveness of marketing campaigns.
b) Controllers: PROMOTORZY TRADING SP. Z O.O. uses service providers who do not act exclusively on instructions and independently determine the purposes and methods of using Customers' personal data. These include providers of electronic payment and banking services.
2. Location: Service providers are based in Poland and other countries within the European Economic Area (EEA).
3. Customer personal data is stored:
a) If the processing of personal data is based on consent, the data is processed by PROMOTORZY TRADING SP. Z O.O. until the consent is withdrawn, and after withdrawal for the period corresponding to the limitation period for claims that PROMOTORZY TRADING SP. Z O.O. may raise and that may be raised against it. If no special regulation states otherwise, the limitation period is six years, and for claims related to periodic services and those related to business activity, three years.
b) If the processing of personal data is based on the performance of a contract, the data is processed by PROMOTORZY TRADING SP. Z O.O. as long as necessary to perform the contract, and after that, for the period corresponding to the limitation period for claims. If no special regulation states otherwise, the limitation period is six years, and for claims related to periodic services and those related to business activity, three years.
4. In case of a purchase in the Online Store, personal data may be shared, depending on the Customer’s choice, with the following entities for the purpose of delivering the ordered goods:
a) A courier company;
b) InPost Paczkomaty Sp. z o.o. with its registered office in Kraków, providing delivery services and handling the parcel locker system.
5. If the Customer chooses to pay via the PayU system, their personal data is shared with PayU S.A. for the purpose of processing the payment.
6. Navigation data may be used to provide better customer service, analyze statistical data, and adjust the Online Store to customers' preferences, as well as to administer the Online Store.
7. If the Customer subscribes to the newsletter, PROMOTORZY TRADING SP. Z O.O. will send electronic messages containing commercial information about promotions and new products available in the Online Store.
8. Upon request, PROMOTORZY TRADING SP. Z O.O. may share personal data with authorized public authorities, including entities of the Prosecutor's Office, Police, President of the Office for Personal Data Protection, President of the Office for Competition and Consumer Protection, or President of the Office of Electronic Communications.
1. The Online Store uses small files called cookies. These are saved by PROMOTORZY TRADING SP. Z O.O. on the end device of a person visiting the Online Store, if the web browser allows it. A cookie file typically contains the domain name from which it originates, its "expiration time," and a randomly selected individual number identifying the file. Information collected using such files helps customize the products offered by PROMOTORZY TRADING SP. Z O.O. to the individual preferences and actual needs of visitors to the Online Store. It also allows for the creation of general statistics on visits to the products displayed in the Online Store.
2. PROMOTORZY TRADING SP. Z O.O. uses two types of cookies:
a) Session cookies: After the session of a given browser ends or the computer is turned off, the saved information is deleted from the device’s memory. The session cookie mechanism does not allow the retrieval of any personal data or confidential information from customers' computers.
b) Persistent cookies: These are stored in the memory of the customer's end device and remain there until they are deleted or expire. The persistent cookie mechanism does not allow the retrieval of any personal data or confidential information from customers' computers.
3. PROMOTORZY TRADING SP. Z O.O. uses its own cookies for the following purposes:
a) Authenticating the customer in the Online Store and ensuring the customer session in the Online Store (after logging in), so the customer does not need to enter their login and password on each subpage of the Online Store;
b) Analyzing and researching, as well as auditing the viewership, particularly for creating anonymous statistics that help understand how customers use the Online Store's website, enabling improvement of its structure and content.
4. PROMOTORZY TRADING SP. Z O.O. uses external cookies for the following purposes:
a) Promoting the Online Store via the social network facebook.com (administrator of external cookies: Facebook Inc., USA or Facebook Ireland, Ireland);
b) Displaying a map indicating the location of PROMOTORZY TRADING SP. Z O.O. office on the Online Store’s informational pages, via the Google Maps service (administrator of external cookies: Google Inc., USA);
c) Displaying opinions and quality marks on the Online Store’s website using the Trustbadge tool (administrator of external cookies: Trusted Shops GmbH, Germany);
d) Authenticating the customer in the Online Store and ensuring the customer session in the Online Store (after logging in) via the social network Facebook.com (administrator of external cookies: Facebook Inc., USA or Facebook Ireland, Ireland);
e) Authenticating the customer in the Online Store and ensuring the customer session in the Online Store (after logging in) via the Google.com service (administrator of external cookies: Google Inc., USA);
f) Collecting general and anonymous statistical data via Google Analytics tools (administrator of external cookies: Google Inc., USA);
g) Displaying the "Reliable Terms and Conditions" certificate via the rzetelnyregulamin.pl website (administrator of external cookies: Rzetelna Grupa sp. z o.o., Warsaw, Poland).
5. The cookies mechanism is safe for the customers' computers. In particular, this mechanism does not allow viruses or other unwanted or malicious software to access customers' computers. However, customers can limit or disable access to cookies through their browsers. If they choose this option, they can still use the Online Store, but certain functions that inherently require cookies may not work.
6. Below is how to change the settings for popular web browsers regarding cookies:
a) Chrome and Chrome Mobile browser;
b) Facebook in-app Browser;
c) Internet Explorer browser;
d) Microsoft EDGE browser;
e) Mozilla Firefox browser;
f) Opera browser;
g) Safari and Safari Mobile browser;
h) Samsung Browser.
7. PROMOTORZY TRADING SP. Z O.O. may collect the IP addresses of customers. The IP address is a number assigned to the computer of a person visiting the Online Store by the Internet service provider. The IP number allows access to the Internet and, in most cases, is dynamically assigned to the computer, meaning it changes with each connection to the Internet. The IP address is used by PROMOTORZY TRADING SP. Z O.O. for diagnosing technical problems with the server, creating statistical analyses (e.g., determining the regions with the most visits), as useful information for administering and improving the Online Store, as well as for security and potential identification of unwanted automated browsing programs that put strain on the server.
8. The Online Store contains links to other websites. PROMOTORZY TRADING SP. Z O.O. is not responsible for the privacy policies applicable to those sites.
1. Right to Withdraw Consent – Legal basis: Art. 7(3) GDPR
a) The customer has the right to withdraw any consent they have given to PROMOTORZY TRADING SP. Z O.O.
b) Withdrawal of consent takes effect from the moment of withdrawal.
c) The withdrawal of consent does not affect any processing done by PROMOTORZY TRADING SP. Z O.O. lawfully prior to its withdrawal.
d) Withdrawal of consent does not result in any negative consequences for the customer, but it may prevent further use of services or functionalities that, by law, PROMOTORZY TRADING SP. Z O.O. can only provide with consent.
2. Right to Object to Data Processing – Legal basis: Art. 21 GDPR
a) The customer has the right to object at any time, on grounds relating to their particular situation, to the processing of their personal data, including profiling, where PROMOTORZY TRADING SP. Z O.O. processes the data based on a legitimate interest, such as marketing products and services, usage statistics, or facilitating the use of the Online Store, as well as satisfaction surveys.
b) Opting out of receiving marketing communications will be considered an objection to processing personal data, including profiling for those purposes.
c) If the objection is valid and PROMOTORZY TRADING SP. Z O.O. has no other legal basis for processing the personal data, the personal data will be deleted.
3. Right to Erasure ("Right to be Forgotten") – Legal basis: Art. 17 GDPR
a) The customer has the right to request the deletion of all or some of their personal data.
b) The customer can request deletion if:
a. the data is no longer necessary for the purposes for which it was collected or processed;
b. the customer withdraws their consent for data processed based on consent;
c. the customer objects to the use of their data for marketing purposes;
d. the data is processed unlawfully;
e. the data must be deleted to comply with a legal obligation under EU or member state law;
f. the data was collected in relation to offering information society services.
c) Despite a deletion request, PROMOTORZY TRADING SP. Z O.O. may retain certain personal data necessary to establish, assert, or defend claims, as well as to comply with a legal obligation requiring processing under EU or member state law.
4. Right to Restrict Processing – Legal basis: Art. 18 GDPR
a) The customer has the right to request the restriction of the processing of their personal data. Until the request is resolved, the customer will not be able to use certain functionalities or services that require processing of the restricted data.
b) The customer can request the restriction of personal data processing in the following cases:
a. when the accuracy of the data is disputed – the processing will be restricted for the time necessary to verify the accuracy, no longer than 7 days;
b. when the processing is unlawful, and instead of deletion, the customer requests the restriction of use;
c. when the data is no longer necessary for processing purposes, but is needed for the customer to establish, exercise, or defend claims;
d. when the customer objects to the use of their data – the restriction lasts for the time necessary to assess whether the protection of the customer’s rights and freedoms prevails over the interests pursued by the administrator.
5. Right to Access – Legal basis: Art. 15 GDPR
a) The customer has the right to obtain confirmation from the administrator regarding the processing of their personal data and, if it occurs, they have the right to:
a. access their personal data;
b. obtain information on the purposes of processing, the categories of data processed, the recipients of the data, the planned retention period, the customer’s rights under GDPR, and the right to lodge a complaint with a supervisory authority, the source of the data, automated decision-making (including profiling), and security measures for data transferred outside the EU;
c. obtain a copy of their personal data.
6. Right to Rectification – Legal basis: Art. 16 GDPR
a) The customer has the right to request the immediate correction of inaccurate personal data. Taking into account the processing purposes, the customer has the right to request the completion of incomplete personal data, including by submitting an additional statement.
7. Right to Data Portability – Legal basis: Art. 20 GDPR
a) The customer has the right to receive their personal data provided to the administrator and send it to another data controller. The customer may also request that the data be transmitted directly to another administrator, if technically feasible. In this case, the administrator will send the personal data in a CSV file format, which is widely used and suitable for machine reading.
8. Request Fulfillment Timeframe
a. The administrator will respond to any request under these rights immediately but no later than within one month of receiving it. If the request is complex, PROMOTORZY TRADING SP. Z O.O. will notify the customer of the extended deadline within one month.
9. Complaint Rights
a. The customer can submit complaints, queries, and requests regarding their personal data processing and the exercise of their rights to the administrator.
10. Standard Contractual Clauses
• The customer has the right to request copies of standard contractual clauses by contacting the administrator as outlined in §7 of the Privacy Policy.
11. Right to Lodge a Complaint
• The customer has the right to lodge a complaint with the President of the Personal Data Protection Office if they believe their data protection rights or other rights under GDPR have been violated.
1. Profiling refers to any form of automated processing of Personal Data that involves using Personal Data to evaluate certain personal factors of a Data Subject, particularly for the analysis or prediction of aspects related to the person's work performance, economic situation, health, personal preferences, interests, reliability, behavior, location, or movement.
2. Customers' Personal Data may be processed in an automated manner (profiling); however, this will not result in any legal effects or significantly affect the Customers' situation.
3. Profiling of personal data by PROMOTORZY TRADING SP. Z O.O. involves processing customers' data both automatically and manually, using it to evaluate certain information about the customer, particularly to analyze or predict their personal preferences and interests.
4. To reach Customers with marketing messages outside of the Online Store's Website, PROMOTORZY TRADING SP. Z O.O. uses the services of external providers. These services involve displaying marketing messages on websites other than the Online Store's Website. To achieve this, external providers install relevant codes or pixels to gather information about the Customer's activity on the Online Store's Website. Details regarding the cookies used are provided in §3. Legal basis – legitimate interest (Art. 6 (1) (f) GDPR), which involves tailoring marketing messages to preferences and interests.
5. To reach Customers with marketing messages through the Online Store's Website, PROMOTORZY TRADING SP. Z O.O. uses the services of external providers. These services involve displaying marketing messages on the Online Store's Website. To achieve this, external providers install relevant codes or pixels to gather information about the Customer's activity on the Online Store's Website. Details regarding the cookies used are provided in §3. Legal basis – legitimate interest (Art. 6 (1) (f) GDPR), which involves tailoring marketing messages to preferences and interests.
6. To reach Customers with marketing messages through the Online Store's Website, PROMOTORZY TRADING SP. Z O.O. uses its own cookie mechanisms to gather information about the Customer's activity on the Online Store's Website. Details regarding the cookies used are provided in §3. Legal basis – legitimate interest (Art. 6 (1) (f) GDPR), which involves tailoring marketing messages to preferences and interests.
1. PROMOTORZY TRADING SP. Z O.O. ensures secure and encrypted communication when transmitting Personal Data and during login to the Customer Account on the Service. PROMOTORZY TRADING SP. Z O.O. uses an SSL certificate issued by one of the leading global companies in the field of security and data encryption over the internet.
2. If a Customer with an account in the Online Store loses their access password in any way, the Online Store allows generating a new password. PROMOTORZY TRADING SP. Z O.O. does not send password reminders. The password is stored in an encrypted form, preventing it from being read. To generate a new password, the Customer must provide an email address in the form available via the "Forgot Password" link, which can be found next to the login form. The Customer will receive an email at the address provided during registration or updated in the last profile change. The email will contain a redirect to a dedicated form available on the Online Store's Website, where the Customer can set a new password.
3. PROMOTORZY TRADING SP. Z O.O. will never send any correspondence, including electronic correspondence, requesting login details, especially the access password to the Customer's account.
1. The Privacy Policy may be amended, and PROMOTORZY TRADING SP. Z O.O. will inform Customers in advance, at least 7 days before the changes take effect.
2. Any questions related to the Privacy Policy should be directed to the email address: sklep@dym.pl