PRIVACY POLICY
CUBEWELD.PL ONLINE STORE
TABLE OF CONTENTS:
GENERAL PROVISIONS
BASIS FOR DATA PROCESSING
PURPOSE, BASIS, AND DURATION OF DATA PROCESSING IN THE ONLINE STORE
DATA RECIPIENTS IN THE ONLINE STORE
PROFILING IN THE ONLINE STORE
RIGHTS OF THE DATA SUBJECT
COOKIES IN THE ONLINE STORE AND ANALYTICS
FINAL PROVISIONS
1.GENERAL PROVISIONS
1.1.This privacy policy of the Online Store is for informational purposes only, which means it does not impose any obligations on Service Recipients or Customers of the Online Store. The privacy policy primarily outlines the rules for processing personal data by the Administrator in the Online Store, including the grounds, purposes, and duration of personal data processing, as well as the rights of data subjects and information on the use of Cookies and analytical tools in the Online Store.
1.2.The administrator of personal data collected via the Online Store is ECAD A. WOJTCZAK, R. ZARĘBSKI SPÓŁKA KOMANDYTOWA based in Łódź (registered office and correspondence address: ul. 3 Maja 64/66, 93-408 Łódź); entered into the Register of Entrepreneurs of the National Court Register under KRS 0001005609; the registry court where the company documentation is kept: District Court for Łódź – Śródmieście in Łódź, 20th Commercial Division of the National Court Register; NIP: 7292652717; REGON: 10058592500000, email address: adam.wojtczak@ecad.com.pl and contact phone number: +48 697691111 – hereinafter referred to as the “Administrator”, who is also the Service Provider of the Online Store and the Seller.
1.3.Personal data in the Online Store is processed by the Administrator in accordance with applicable law, in particular 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 referred to as “GDPR” or “GDPR Regulation”. Official text of the GDPR Regulation: http://eur-lex.europa.eu/legal-content/PL/TXT/?uri=CELEX%3A32016R0679
1.4.Use of the Online Store, including making purchases, is voluntary. Likewise, providing personal data by the Service Recipient or Customer using the Online Store is voluntary, with two exceptions: (1) conclusion of contracts with the Administrator – failure to provide the personal data necessary for concluding and performing a Sales Agreement or Electronic Service agreement with the Administrator, as indicated on the Online Store website and in the Store Regulations and this privacy policy, will result in the inability to conclude such an agreement. In this case, providing personal data is a contractual requirement, and if the data subject wishes to conclude an agreement with the Administrator, they are obliged to provide the required data. The scope of data required to conclude a contract is always indicated in advance on the Online Store website and in the Store Regulations; (2) statutory obligations of the Administrator – providing personal data is a legal requirement arising from generally applicable laws imposing an obligation on the Administrator to process personal data (e.g., data processing for tax or accounting purposes), and failure to provide such data will prevent the Administrator from fulfilling these obligations.
1.5.The Administrator takes special care to protect the interests of data subjects whose personal data it processes, and in particular is responsible for and ensures that the data collected is: (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 it is processed; (4) stored in a form that permits identification of the data subject for no longer than is necessary for the purposes of processing; and (5) processed in a manner that ensures 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 varying likelihood and severity of harm to the rights or freedoms of natural persons, 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 persons from acquiring or modifying personal data transmitted electronically.
1.7.All words, expressions, and acronyms used in this privacy policy and beginning with a capital letter (e.g., Seller, Online Store, Electronic Service) should be understood in accordance with their definition in the Store Regulations available on the Online Store website.
2.BASIS FOR DATA PROCESSING
2.1.The Administrator is entitled to process personal data if – and to the extent that – at least one of the following conditions is met: (1) the data subject has given consent to the processing of their personal data for one or more specific purposes; (2) processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject 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 the purposes of the 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 data subject which require protection of personal data, in particular where the data subject is a child.
2.2.Processing of personal data by the Administrator always requires at least one of the bases indicated in point 2.1 of the privacy policy. The specific bases for processing personal data of Service Recipients and Customers of the Online Store by the Administrator are indicated in the next section of the privacy policy – in relation to the given purpose of data processing by the Administrator.
3.PURPOSE, BASIS, AND DURATION OF DATA PROCESSING IN THE ONLINE STORE
3.1.In each case, the purpose, basis, duration, and recipients of personal data processed by the Administrator result from actions taken by the given Service Recipient or Customer in the Online Store or by the Administrator. For example, if a Customer decides to make a purchase in the Online Store and chooses personal pickup of the purchased Product instead of courier delivery, their personal data will be processed for the purpose of performing the concluded Sales Agreement, but will not be shared with the carrier performing deliveries on behalf of the Administrator.
3.2.The Administrator may process personal data within the Online Store for the following purposes, on the bases, and for the periods indicated in the table below:
Purpose of data processing
Legal basis for data processing
Data retention period
Performance of the Sales Agreement or Electronic Service agreement or taking steps at the request of the data subject prior to entering into such agreements
Article 6(1)(b) of the GDPR (performance of a contract) – processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject prior to entering into a contract
Data is stored for the period necessary to perform, terminate, or otherwise expire 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 the purposes of the legitimate interests pursued by the Administrator – consisting in caring for the interests and good image of the Administrator, its Online Store, and striving to sell Products
 
Data is stored for the period of the legitimate interest pursued by the Administrator, but no longer than the limitation period for claims by the Administrator against the data subject arising from the business activity conducted by the Administrator. The limitation period is specified by law, in particular the Civil Code (the basic limitation period for claims related to business activity is three years, and for the Sales Agreement two years).
The Administrator may not process data for direct marketing purposes if the data subject has effectively objected to such processing.
Marketing
Article 6(1)(a) of the GDPR (consent) – the data subject has consented to the processing of their personal data for marketing purposes by the Administrator
Data is stored until the data subject withdraws consent for further processing of their data for this purpose.
Customer feedback on the concluded Sales Agreement
Article 6(1)(a) of the GDPR – the data subject has consented to the processing of their personal data for the purpose of providing feedback
Data is stored until the data subject withdraws consent for further processing of their data for this purpose.
Keeping accounting records
Article 6(1)(c) of the GDPR in connection with Article 74(2) of the Accounting Act of 30 January 2018 (Journal of Laws of 2018, item 395, as amended) – processing is necessary for compliance with a legal obligation to which the Administrator is subject
Data is stored for the period required by law obliging the Administrator to keep accounting records (5 years, counting from the beginning of the year following the financial year to which the data relates).
Establishing, pursuing, or defending claims that may be raised by the Administrator or against the Administrator
Article 6(1)(f) of the GDPR (legitimate interest of the administrator) – processing is necessary for the purposes of the legitimate interests pursued by the Administrator – consisting in establishing, pursuing, or defending claims that may be raised by the Administrator or against the Administrator
Data is stored for the period of the legitimate interest pursued by the Administrator, but no longer than the limitation period for claims that may be raised against the Administrator (the basic limitation period for claims against the Administrator is six years).
Use of the Online Store website and ensuring its proper functioning
Article 6(1)(f) of the GDPR (legitimate interest of the administrator) – processing is necessary for the purposes of the legitimate interests pursued by the Administrator – consisting in operating and maintaining the Online Store website
Data is stored for the period of the legitimate interest pursued by the Administrator, but no longer than the limitation period for claims by the Administrator against the data subject arising from the business activity conducted by the Administrator. The limitation period is specified by law, in particular the Civil Code (the basic limitation period for claims related to business activity is three years, and for the Sales Agreement two years).
Compiling statistics and analyzing traffic in the Online Store
Article 6(1)(f) of the GDPR (legitimate interest of the administrator) – processing is necessary for the purposes of the legitimate interests pursued by the Administrator – consisting in compiling statistics and analyzing traffic in the Online Store to improve its functioning and increase sales of Products
Data is stored for the period of the legitimate interest pursued by the Administrator, but no longer than the limitation period for claims by the Administrator against the data subject arising from the business activity conducted by the Administrator. The limitation period is specified by law, in particular the Civil Code (the basic limitation period for claims related to business activity is three years, and for the Sales Agreement two years).
4.DATA RECIPIENTS IN THE ONLINE STORE
4.1.For the proper functioning of the Online Store, including the execution of concluded Sales Agreements, it is necessary for the Administrator to use the services of external entities (such as software providers, couriers, or payment service providers). The Administrator uses only such processors who provide sufficient guarantees to implement appropriate technical and organizational measures so that processing meets the requirements of the GDPR Regulation and protects the rights of data subjects.
4.2.Personal data may be transferred by the Administrator to a third country, provided that the Administrator ensures that, in such a case, the data is transferred to a country providing an adequate level of protection – in accordance with the GDPR Regulation, and in the case of other countries, that the transfer is based on standard data protection clauses. The Administrator ensures that the data subject has the opportunity to obtain a copy of their data. The Administrator transfers collected personal data only when and to the extent necessary to achieve the specific purpose of data processing in accordance with this privacy policy.
4.3.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 the specific purpose of personal data processing and only to the extent necessary for its implementation. For example, if a Customer uses personal pickup, their data will not be transferred to the carrier cooperating with the Administrator.
4.4.Personal data of Service Recipients and Customers of the Online Store may be transferred to the following recipients or categories of recipients:


carriers / freight forwarders / courier brokers / entities handling warehousing and/or shipping processes – in the case of a Customer who uses the delivery method of the Product by postal or courier shipment in the Online Store, the Administrator provides the collected personal data of the Customer to the selected carrier, freight forwarder, or intermediary performing shipments on behalf of the Administrator, and if the shipment is made from an external warehouse – to the entity handling warehousing and/or shipping processes – to the extent necessary to deliver the Product to the Customer.
entities handling electronic or card payments – in the case of a Customer who uses electronic or card payment methods in the Online Store, the Administrator provides the collected personal data of the Customer to the selected entity handling such payments in the Online Store on behalf of the Administrator to the extent necessary to process the payment made by the Customer.
lending institutions / lessors – in the case of a Customer who uses an installment payment or leasing method in the Online Store, the Administrator provides the collected personal data of the Customer to the selected lender or lessor handling such payments in the Online Store on behalf of the Administrator to the extent necessary to process the payment made by the Customer.
providers of review survey systems – in the case of a Customer who has agreed to provide feedback on the concluded Sales Agreement, the Administrator provides the collected personal data of the Customer to the selected provider of the review survey system for concluded Sales Agreements in the Online Store on behalf of the Administrator to the extent necessary for the Customer to provide feedback using the review survey system.
service providers supplying the Administrator with technical, IT, and organizational solutions enabling the Administrator to conduct business activities, including the Online Store and Electronic Services provided through it (in particular, providers of computer software for running the Online Store, email and hosting providers, and providers of software for business management and technical support for the Administrator) – the Administrator provides the collected personal data of the Customer to the selected provider acting on its behalf only when and to the extent necessary to achieve the specific purpose of data processing in accordance with this privacy policy.
providers of accounting, legal, and advisory services supporting the Administrator with accounting, legal, or advisory assistance (in particular, accounting offices, law firms, or debt collection companies) – the Administrator provides the collected personal data of the Customer to the selected provider acting on its behalf only when and to the extent necessary to achieve the specific purpose of data processing in accordance with this privacy policy.
providers of social plugins, scripts, and other similar tools placed on the Online Store website that enable the browser of the person visiting the Online Store website to download content from the providers of these plugins (e.g., login using social network credentials) and, for this purpose, transfer the personal data of the visitor to these providers, including: Meta Platforms Ireland Ltd. – the Administrator uses Facebook social plugins on the Online Store website (e.g., Like, Share button, or login using Facebook credentials) and, in connection with this, collects and provides the personal data of the Service Recipient using the Online Store website to Meta Platforms Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland) to the extent and in accordance with the privacy rules available here: https://www.facebook.com/about/privacy/ (this data includes information about activities on the Online Store website – including device information, visited sites, purchases, displayed ads, and how services are used – regardless of whether the Service Recipient has a Facebook account and whether they are logged in to Facebook).
5.PROFILING IN THE ONLINE STORE
5.1.The GDPR Regulation imposes an obligation on the Administrator to inform about automated decision-making, including profiling as referred to in Article 22(1) and (4) of the GDPR Regulation, and – at least in those cases – important information about the principles of their making, as well as the significance and expected consequences of such processing for the data subject. With this in mind, the Administrator provides information in this section of the privacy policy about possible profiling.
5.2.The Administrator may use profiling in the Online Store for direct marketing purposes, but decisions made on its basis by the Administrator do not concern the conclusion or refusal to conclude a Sales Agreement or the possibility to use Electronic Services in the Online Store. The result of using profiling in the Online Store may be, for example, granting a discount to a person, sending a discount code, reminding about unfinished purchases, sending a proposal for a Product that may match the interests or preferences of a person, or offering better terms compared to the standard offer of the Online Store. Despite profiling, it is up to the person to decide whether they wish to use the discount or better terms received in this way and make a purchase in the Online Store.
5.3.Profiling in the Online Store consists of automatic analysis or prediction of a person’s behavior on the Online Store website, e.g., by adding a specific Product to the cart, browsing the page of a specific Product in the Online Store, or by analyzing the purchase history in the Online Store. Such profiling requires the Administrator to have the person’s personal data in order to send, for example, a discount code.
5.4.The data subject 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 DATA SUBJECT
6.1.Right of access, rectification, restriction, erasure, or data portability – the data subject has the right to request from the Administrator access to their personal data, rectification, erasure (“right to be forgotten”), or restriction of processing, as well as the right to object to processing, and the right to data portability. Detailed conditions for exercising these rights are set out in Articles 15-21 of the GDPR Regulation.
6.2.Right to withdraw consent at any time – if the data subject’s data is processed by the Administrator based on consent (under Article 6(1)(a) or Article 9(2)(a) of the GDPR Regulation), they have 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 – if the data subject’s data is processed by the Administrator, they have the right to lodge a complaint with a supervisory authority in the manner and procedure specified in the GDPR Regulation and Polish law, in particular the Personal Data Protection Act. The supervisory authority in Poland is the President of the Personal Data Protection Office.
6.4.Right to object – the data subject 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 tasks) or (f) (legitimate interest of the administrator), including profiling based on these provisions. In such a case, the Administrator may no longer process this personal data unless they demonstrate compelling legitimate grounds for the processing overriding the interests, rights, and freedoms of the data subject 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 data subject has the right to object at any time to the processing of their personal data for such marketing, including profiling to the extent that it is related to such direct marketing.
6.6.To exercise the rights referred to in this section of the privacy policy, you can contact the Administrator by sending a relevant message in writing or by email to the Administrator’s address indicated at the beginning of the 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 files sent by a server and stored on the device of the person visiting the Online Store website (e.g., on a computer hard drive, laptop, or smartphone memory card – depending on the device used to visit our Online Store). Detailed information about Cookies and their history can be found, among others, here: https://pl.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:
By provider:
own (created by the Administrator’s Online Store website) and
third-party (other than the Administrator)
By storage period on the device of the person visiting the Online Store website:
session (stored until logging out of the Online Store or closing the web browser) and
persistent (stored for a specified time defined by the parameters of each file or until manually deleted)
By purpose of use:
essential (enabling the proper functioning of the Online Store website),
functional/preference (allowing customization of the Online Store website to the preferences of the person visiting the site),
analytics and performance (collecting information on how the Online Store website is used),
marketing, advertising, and social (collecting information about the person visiting the Online Store website to display ads to them, personalize them, measure effectiveness, and conduct other marketing activities, including on websites separate from the Online Store website, such as social media portals or other sites belonging to the same advertising networks as the Online Store)
7.3.The Administrator may process data contained in Cookies when visitors use the Online Store website for the following specific purposes:
Purposes of using Cookies in the Administrator’s Online Store
identifying Service Recipients as logged in to the Online Store and showing that they are logged in (essential Cookies)
remembering Products added to the cart for placing an Order (essential Cookies)
remembering data from completed Order Forms, surveys, or login data to the Online Store (essential and/or functional/preference Cookies)
customizing the content of the Online Store website to the individual preferences of the Service Recipient (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 (analytics and performance Cookies)
displaying and rendering ads, limiting the number of ad impressions, and ignoring ads that the Service Recipient does not want to see, measuring ad effectiveness, as well as personalizing ads, i.e., analyzing the characteristics of visitors to the Online Store through anonymous analysis of their actions (e.g., repeated visits to specific pages, keywords, etc.) to create their profile and provide them with ads tailored to their predicted interests, including when they visit other websites in the advertising network of Google Ireland Ltd. and Facebook, i.e., Meta Platforms Ireland Ltd. (marketing, advertising, and social Cookies)
7.4.To check in the most popular web browsers which Cookies (including their duration and provider) are currently being sent by the Online Store website, you can do the following:
In Chrome:
(1) Click the padlock icon to the left of the address bar, (2) go to the “Cookies” tab.
In Firefox:
(1) Click the shield icon to the left of the address bar, (2) go to the “Allowed” or “Blocked” tab, (3) click the “Cross-site tracking cookies”, “Social media trackers”, or “Content with trackers” field.
In Internet Explorer:
(1) Click the “Tools” menu, (2) go to the “Internet Options” tab, (3) go to the “General” tab, (4) go to the “Settings” tab, (5) click the “View files” field.
In Opera:
(1) Click the padlock icon to the left of the address bar, (2) go to the “Cookies” tab.
In Safari:
(1) Click the “Preferences” menu, (2) go to the “Privacy” tab, (3) click the “Manage website data” field.
Regardless of the browser, using tools available, for example, at: https://www.cookiemetrix.com/ or: https://www.cookie-checker.com/
7.5.By default, most web browsers available on the market accept the storage of Cookies. Everyone can define the conditions for using Cookies through their browser settings. This means, for example, that you can partially limit (e.g., temporarily) or completely disable the ability to save Cookies – in the latter case, however, this may affect some functionalities of the Online Store (for example, it may not be possible to complete the Order process via the Order Form due to Products not being remembered in the cart during subsequent steps of placing an Order).
7.6.Browser settings regarding Cookies are important from the perspective of consent to the use of Cookies by our Online Store – according to the law, such consent may also be given through browser settings. Detailed information on changing Cookie settings and deleting them independently in the most popular web browsers is available in the browser’s help section and at the following links (just click the link):
in Chrome
in Firefox
in Internet Explorer
in Opera
in Safari
in Microsoft Edge
7.7.The Administrator may use Google Analytics, Universal Analytics services provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) in the Online Store. These services help the Administrator compile statistics and analyze traffic in the Online Store. The data collected is processed within these services to generate statistics helpful in administering the Online Store and analyzing traffic in the Online Store. This data is aggregate in nature. When using these services in the Online Store, the Administrator collects such data as the sources and medium of visitors to the Online Store and how they behave on the Online Store website, information about the devices and browsers from which they visit the website, IP and domain, geographic and demographic data (age, gender), and interests.
7.8.It is possible for a person to easily block the sharing of information about their activity on the Online Store website with Google Analytics – for example, by installing a browser add-on provided by Google Ireland Ltd. available here: https://tools.google.com/dlpage/gaoptout?hl=pl.
7.9.Due to the possibility of the Administrator using advertising and analytics services provided by Google Ireland Ltd. in the Online Store, the Administrator indicates that full information on the rules for processing data of visitors to the Online Store (including information stored in Cookies) by Google Ireland Ltd. is available in the privacy policy of Google services at: https://policies.google.com/technologies/partner-sites.
7.10.The Administrator may use the Meta Pixel service provided by Meta Platforms Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) in the Online Store. This service helps the Administrator measure the effectiveness of advertisements and learn what actions visitors to the online store take, as well as display tailored ads to those people. Detailed information about the Meta Pixel can be found at: https://www.facebook.com/business/help/742478679120153?helpref=page_content.
7.11.You can manage the operation of the Meta Pixel through the ad 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, after going to other sites, to read the privacy policy established there. This privacy policy applies only to the Administrator’s Online Store.