- The Online Store Owner and also the data controller is HINT GROUP Sp. z o.o. with registered office in Warsaw (00-876), ul. Ogrodowa 58, entered into the register of entrepreneurs of the National Court Register kept by the Sąd Rejonowy dla m.st. Warszawy w Warszawie, XII Economic Department of the National Court Register under number KRS 0000621708, share capital of PLN 51.000, NIP (tax identification number): 5272772044, REGON (Polish business registry number): 364654521, hereinafter referred to as HINT GROUP Sp. z o.o..
- Personal data collected by HINT GROUP Sp. z o.o. via the Online Store are processed in compliance 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 also referred to as GDPR.
- HINT GROUP Sp. z o.o. acts with utmost care to ensure privacy of the Customers, who visit the Online Store.
Type of processed data, objectives and legal ground
- HINT GROUP Sp. z o.o. collects information on natural persons performing a legal transaction, which is not related directly to their business activity (consumers), hereinafter referred to as Customers.
- Personal data of Customers are collected in case of:
- registration of an account in the Online Store for the purpose of establishment and management of an individual account. Legal grounds: processing is necessary for the performance of a contract on establishment and management of an Account service (article 6 sec. 1 letter b of GDPR);
- subscription of the Newsletter for the purpose of the performance of a contract concerning a service rendered by electronic means. Legal grounds – consent of a data subject for the performance of a contract concerning Newsletter service (article 6 sec. 1 letter a of GDPR).
- During registration of an account in the Online Store, the Customer shall provide:
- e-mail address;
- post code.
- sex and date of birth.
- During registration of an account in the Online Store, the Customer defines an individual access password to their account. The Customer may change an account later in compliance with principles defined in Article 6.
- When using the Newsletter service, the Customer shall provide their e-mail address only.
- Additional information may be collected when the Customer uses the Online Store Website, in particular an IP address assigned to the Customer’s computer or an external IP address of your internet provider, domain name, type of a browser, access time, type of the operating system.
- Also navigation data may be collected from the Customers, including information on links and references they click or other activities undertaken by them in our Online Store. Legal grounds- legitimate interests (article 6 sec. 1 letter f of GDPR) in form of facilitation of use of services rendered by electronic means and improvement of functionality of such services.
- To determine, exercise and enforce claims, come personal data provided by the Customer when using functionalities of the Online Store may be provided, such as: name, surname, information about use of services, if claims result from the manner of user of services by the Customer, other data necessary to prove existence of claim, including the volume of suffered losses. Legal grounds- legitimate interests (article 6 sec. 1 letter f of GDPR) in form of determination, exercising and enforcement of claims and defence against claims in litigation and proceeding in front of other public authorities.
- Personal data are provided to HINT GROUP Sp. z o.o. on voluntary basis in relation to concluded sales contracts or services rendered via the Online Store Website, provided that, however, without data specified in the data forms in the Registration process, Registration and establishment of a Customer Account is not possible, and if orders are placed without Registration of Customer Account, placement and fulfilment of Customer order will be impossible.
To whom are data disclosed or provided and how long are they stored?
- Customer’s personal data are provided to providers of services used by HINT GROUP Sp. z o.o. when operating the Online Store depending on contractual arrangements and circumstances, they are either subject to HINT GROUP Sp. z o.o.’s instructions about manners and ways of data processing (processors) or they define purposes and manners of processing on their own (data controllers).
- Processors. HINT GROUP Sp. z o.o. uses services of providers processing data on HINT GROUP Sp. z o.o.’s request only. They include for instance hosting providers, accounting services, providers of marketing systems, systems of traffic analysis in the Online Store, systems for analysis of marketing campaign efficiency;
- Controllers. HINT GROUP Sp. z o.o. uses services of providers that do not act on request only, but they define the objectives and manners of use of Customers’ personal data. They render electronic payment and banking services.
- Location. Providers of services have their registered offices mainly in Poland and other countries of the European Economic Area (EEA).
- Customers’ personal data are stored:
- If Customer’s personal data are processed on the basis of a consent, they shall be processed by HINT GROUP Sp. z o.o. until the consent is not cancelled, and after cancellation of the consent – for a period of time corresponding to the period of limitation of claims that may be raised by or against HINT GROUP Sp. z o.o.. If it is not provided otherwise in a specific provision, period of limitation amounts to 10 years, and in case of claims concerning periodical services or claims related to business activity – three years;
- If personal data are processed on the basis of execution of the contract, then the Customers’ personal data shall be processed by HINT GROUP Sp. z o.o. as long, as it is necessary for execution of the contract, and afterwards – for a period of time corresponding to the period of limitation of claims. If it is not provided otherwise in a specific provision, period of limitation amounts to 10 years, and in case of claims concerning periodical services or claims related to business activity – three years.
- Navigation data may be used in order to provide Customers with better services, statistical data analysis and adjustment of the Online Store to Customer preferences and to operate the Online Store.
- If the Customer subscribes the Newsletter, HINT GROUP Sp. z o.o. shall send to the Customer’s e-mail address electronic messages with commercial information about promotions and new products available in the Online Store.
- In case of a respective request, HINT GROUP Sp. z o.o. discloses personal data to authorised state authorities, in particular to organisational units of the prosecutor’s office, the Police, the Chairperson of the Personal Data Protection Office, the Chairperson of the Office of Competition and Consumer Protection or the Chairperson of the Office of Electronic Communications.
Cookie files, IP address
- The Online Store uses small files called cookies. They are stored by HINT GROUP Sp. z o.o. on the terminal device of a visitor to the Online Store, if it is allowed by an Internet browser. A cookie file contains usually a domain name, from which it originates, its “expiry time” and individual randomly selected number that identifies such file. Information collected via such type of files enables adjustment of HINT GROUP Sp. z o.o. products to individual preferences and actual needs of visitors to the Online Store. It offers a possibility to prepare general statistics of visits of products presented in the Online Store.
- HINT GROUP Sp. z o.o. uses two types of cookie files:
- Session cookies: after end of a given session of a browser or switch off of a computer they are deleted from computer memory. The mechanism of session cookies does not enable collection of any personal data or confidential information from Customer’s computers;
- Permanent cookies: are stored in the memory of Customer’s terminal device and stay there until they are deleted or expire. The mechanism of permanent cookies does not enable collection of any personal data or confidential information from Customer’s computers.
- HINT GROUP Sp. z o.o. uses own cookies for the purpose of:
- authorisation of the Customer in the Online Store and ensuring Customer’s session in the Online Store (after logging), thanks to which the Customer does not need to type in a login and a password on every page of the Online Store;
- analyses and studies, and audience measurement, in particular to prepare anonymous statistics which support understanding of the manner of use of the Online Store Website by Customers, which enables improvement of its structure and contents.
- HINT GROUP Sp. z o.o. uses external cookies for the purpose of:
- popularisation of the Store via social network facebook.com (controller of external cookies: Facebook Inc with registered office in the US lub Facebook Ireland with registered office in Ireland);
- presentation of the map with localisation of HINT GROUP Sp. z o.o.’s office on the Online Store’s information pages by means of portal maps.google.com (controller of external cookies: Google Inc with registered office in the US);
- collecting general and anonymous statistical data by means of analytic tools Google Analytics (controller of external cookies: Google Inc with registered office in the US);
- Presentation of Reliable Regulation Certificate via website rzetelnyregulamin.pl (external cookie controller: Rzetelna Grupa sp. z o.o. with registered office in Warsaw).
- The cookie mechanism is safe for computers of the Online Store Customers. In particular, no viruses or other unwanted or malicious software may invade Customer computers this way. Still, in their browsers Customers have a possibility to restrict or switch off access of cookie files to computers. If such option is activated, the Online Store may be used save for functions that due to their nature require cookie files.
- Below we present how to change setting of popular internet browsers in respect to cookie files:
- Internet Explorer browser
- Microsoft EDGE browser
- Mozilla Firefox browser
- Chrome browser
- Safari browser
- Opera browser
- HINT GROUP Sp. z o.o. may store IP addresses of the Customers. IP address is a number assigned to a computer of a visitor in the Online Store, by an internet provider. IP number enables access to the Internet. In the majority of cases it is assigned dynamically to a computer, that is it changes for each connection with the Internet, and that is why it is commonly treated non-personal identifying information. IP address is used by HINT GROUP Sp. z o.o. for detection of technical problems with the server, preparation of statistical analyses (e.g. determination, from what regions the majority of visitors come from), as information helping with administration and improvement of the Online Store and for safety purposes and possible identification of unwanted automatic programmes searching through the contents of the Online Store that load the server.
- The Online Store contains links and references to other websites. HINT GROUP Sp. z o.o. shall not be held liable for privacy protection principles in force on such websites.
Rights of data subjects
- The right to withdraw consent – legal ground: article 7 sec. 3 of GDPR.
- The Customer has a right to withdraw consent granted to HINT GROUP Sp. z o.o..
- Withdrawal of consent shall be effective as the time of withdrawal.
- Withdrawal of consent shall not affect the lawfulness of processing before its withdrawal. ;
- Withdrawal of consent shall not entail any negative consequences for the Customer, but may prevent them from further use of services of functionalities, which may be lawfully provided by HINT GROUP Sp. z o.o. only upon consent of the Customer.
- Right to object to personal data processing - legal ground: article 21 of GDPR.
- The Customer shall have the right to object, on grounds relating to their particular situation, at any time to processing of personal data concerning them, including profiling, if HINT GROUP Sp. z o.o. processes their data on the basis of a legitimate interest, such e.g. marketing of HINT GROUP Sp. z o.o.’s products and services, statistic concerning use of individual functionalities of the Online Store and facilitation of use of the Online Store, and Customer satisfaction surveys;
- An e-mail resignation from marketing communications on products or services will mean the Customer’s objection to processing of their personal data, including profiling for those purposes;
- If the Customer’s objection is reasonable and HINT GROUP Sp. z o.o. has no other legal grounds to process personal data, the Customer’s personal data, whose processing has been objected by the Customer, will be deleted.
- Right to erasure (“right to be forgotten” ) - legal ground: article 17 of GDPR.
- The Customer has the right to demand erasure of all or some personal data;
- The Customer has the right to demand the erasure of some personal data, if:
- the personal data are no longer necessary in relation to the purposes for which they were collected or processed;
- the Customer has withdrawn consent in the scope in which personal data have been processed on the basis of their consent;
- the Customer has objected to use of their data for marketing purposes;
- the personal data are unlawfully processed;
- the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which HINT GROUP Sp. z o.o. is subject;
- the personal data have been collected in relation to the offer of information society services.
- Despite of demand of erasure of personal data in relation to an objection or withdrawal of consent, HINT GROUP Sp. z o.o. may retain some full personal data in the scope, in which processing is necessary for determination, claiming or defence against claims, and for fulfilment of the legal obligation requiring data processing under the legislation of the European Union or a Member State to which HINT GROUP Sp. z o.o. is subject. It refers in particular to: name, surname, e-mail address, which are retained for the purpose of examination of complaints and claims related to use of HINT GROUP Sp. z o.o. services, or additionally an address of residence/ correspondences, order number, which are retained for the purpose of examination of complaints and claims related to concluded sales agreements or service agreements.
- Right to restriction of processing- legal ground: article 18 of GDPR.
- The Customer shall have the right to obtain from the controller restriction of their personal data processing. Submission of such demand, until its examination, prevents the use of specified functionalities or services, the use of which would be related with processing of personal data subject to such demand. Moreover, HINT GROUP Sp. z o.o. will not send any message, including marking communications. ;
- The Customer shall have the right to demand restriction of their personal data processing in the following cases:
- When they contest the acccuracy of their personal data; then HINT GROUP Sp. z o.o. shall restrict their use for a period enabling verification of the accuracy of the personal data, but no longer than for 7 days;
- When data processing is unlawful and the Customer demands restriction of their use instead of their erasure;
- When personal data are no longer necessary for the purposes of their collection or use, but they are needed by the Customer in order to determine, exercise or defend claims;
- When the Customer objected to proceeding of their data- then the restriction is introduced for a period necessary to consider whether, due to exceptional circumstances – protection of the Customer’s interests, rights and freedoms prevails over the interests, which are exercise by the Controller when proceeding Customer’s personal data.
- Right of access to data - legal ground: article 15 of GDPR.
- The Customer shall have the right to obtain a confirmation from the Controller, whether or not it processes personal data, and if yes, the Customer shall have the right to:
- obtain access to their personal data;
- obtain information on the purposes of the processing, the categories of processes personal data, the recipients or categories of recipients of such data, the envisaged period for which the personal data will be stored or the criteria used to determine that period (if determination of the planned period of data processing is not possible), on Customer’s rights under the GDPR and the right to lodge a complaint with a supervisory authority, on the source of such data, automated decision-making, including profiling and security devices applied due to the transfer of such data outside the European Union;
- obtain copies of their personal data.
- Right to rectification - legal ground: article 16 of GDPR
- Right to data portability- legal ground: article 20 of GDPR.
- The Customer shall have the right to obtain their personal data, which were provided to the Controller, and then to send them to another data controller selected by the Customer. The Customer shall have the right to demand that such personal data are sent directly by us to another data controller, if this is technically feasible. In such case the Controller shall sent the Customer’s personal data in a csv file, which is a commonly used machine-readable format, allowing transfer of processed data to another data controller.
- If the Customer wishes to exercise any of the foregoing rights, HINT GROUP Sp. z o.o. fulfils a request or refuses to fulfil it promptly, but no later than within a month of its receipt. If, however, due to a complex nature of a demand or a number of demands HINT GROUP Sp. z o.o. is not able to fulfil demand within one month, it shall fulfil it during the following two month, notifying the Customer earlier within a month from receipt of the demand on the intended prolongation of the period and about own activities.
- The Customer may file complaints, questions or requests concerning processing of their personal data and execution of this rights.
- The Customer shall have the right to file a complaint to the Chairperson of the Office of Personal Data Protection in respect to violation of their rights for personal data processing or other rights granted under the GDPR.
Services tailored to preferences and interests (profiling)
- Profiling means any form of automated processing of personal data, which involves the use of personal data to assess some of the given person's personal factors, in particular to analyze or forecast aspects concerning the effects of the work of that individual, his/her economic situation, health, personal preferences, interests, credibility, behavior, location or movement.
- Customers' personal data may be processed in an automated manner (profiling), however, it will not cause any legal effects or have a significant effect on the situation of clients.
- Personal data profiling consists in the processing of customer data in an automated and manual manner, by using them to assess certain customer information, in particular to analyze or forecast its personal preferences and interests.
Security management – the password
- HINT GROUP Sp. z o.o. ensures safe and encrypted connection to the Customers during transfer of personal data and logging to the Customer Account on the Portal. HINT GROUP Sp. z o.o. uses SSL certificate issued by one of the world leaders in respect to security and encryption of data sent via the Internet.
- If the Customer, who has an account in the Online Store, losses their password anyhow, the Online Store enables generation of a new password. HINT GROUP Sp. z o.o. shall not send a password reminder. The password is stored in a database in an encrypted form, which prevents from its reading. To generate a new password, the Customer should provide e-mail address in a form available at a link entitled “Do not remember password?”, next to the account logging form in the Online Store. A new password will be sent automatically to the e-mail address provided during registration or recorded during the last change of the account profile.
- HINT GROUP Sp. z o.o. does not send any correspondence, including electronic correspondence with a request for provision of logging data, in particular the password to the Customer’s Account.
- Date of the last modification: 24.05.2018