Privacy and cookies policy
This document regulates the Privacy and Cookies Policy of the online store Best Sub Europe Sp. z o.o. Sp. K. operated via the webpage made available at the address: shop.bestsublimation24.eu, hereinafter the "Store".
The Store is managed by Best Sub Europe Sp. z o.o. Sp. K. with its registered seat in Lipiany, ul. Myśliborska 8, entered into the Central Register of Data and Information on Business Activities kept by the Minister of Development, of Tax Reference Number NIP: PL 853 152 61 53 and of Business Entity Index Number [REGON]: 386439662, hereinafter the "Seller". The Seller is accessible at the following telephone number: 665 655 653 or at this e-mail address: email@example.com
In this document, we also refer to the relevant technologies involved in data processing. Those include e.g.: support of browser memory, geolocalisation, or pixel tags.
As regards cookies policy, we inform whom it may concern about the conditions of storing information or acquiring access to information already being stored in telecommunications terminal equipment. The end-user shall be deemed a natural person or entity using publicly accessible telecommunications service or requesting that such services be provided to satisfy its own needs.
In order to achieve the primary aim, which is to respect the privacy of Customers, we do our best to ensure due diligence. To meet this objective, we implement the norms and principles envisaged by the universally applicable provisions of the law. Those include in particular:
- the Law of 29 August 1997 on protection of personal data (Journal of Laws of 2016, No. 0, item 922 as amended),
- the Law of 18 July 2002 on provision of services by electronic means (Journal of Laws of 2016, No. 0, item 1030 as amended),
- the Law of 16 July 2004 Telecommunications Law (Journal of Laws of 2016, No. 0, item 1489 as amended).
Specifically, we make every reasonable effort to ensure that the Customer’s data:
- be processed in accordance with the law,
- be collected for the purposes referred to herein and consistent with the law,
- be factually correct and adequate for the purposes for which they are processed,
- be suitably protected from access by unauthorised persons, destruction, disclosure or unlawful use,
- be stored in a format ensuring identification of persons for not longer than necessary to attain the objectives of processing.
The data processed by the Seller shall be stored within the premises of the Company as well as on external, safe and professional servers, in pursuance of contracts concluded by the Seller. Such contracts take into account an appropriate level of data protection.
3. ADMINISTRATOR OF PERSONAL DATA
The administrator of personal data shall be Best Sub Europe Sp. z o.o. Sp. K. with its registered seat in Lipiany, ul. Myśliborska 8, accessible at the telephone number: 665 655 653 or via the e-mail address: firstname.lastname@example.org
4. LEGAL BASIS FOR PERSONAL DATA PROCESSING
We process the personal data of the Customers using the services provided by electronic means through the Store, on condition that:
- it is necessary to establish relations, form the content, amend or terminate the legal relationship between the Customer and the Seller in respect of the following data: full name of the Customer, address for correspondence, telephone number, address of electronic mail;it is necessary to establish relations, form the content, amend or terminate the legal relationship between the Customer and the Seller in respect of the following data: full name of the Customer, address for correspondence, telephone number, address of electronic mail;
- it is implemented for the purpose of performing contracts or performing any legal act with the Customer, if it proves necessary on account of the services provided or the manner of settlement thereof,
- it is substantiated by the objective to characterise the manner of the Customer use of the services provided by electronic means through the Store regarding the operating data i.e. containing designation ensuring identification of the telecommunications terminal or data-communication system used by the Customer, information on commencing, ending and on the extent of each use of the service provided by electronic means, and information on the Customer’s use services provided by electronic means.
We do not process the foregoing personal data upon termination of the Customer’s use of the service provided by electronic means, yet subject to the reservation of possible further use of those from among the aforementioned data deemed:
- necessary to ensure settlement of the service and to pursue claims on account of payments for using the service,
- necessary for advertising purposes, studies of the market and of consumer behaviour and preferences with the study results intended to ensure improvement of quality of service provided by the Seller with the Customer’s agreement,
- necessary to clarify the circumstances of any unauthorised use of the service,
- allowed for processing under separate Laws or contracts.
We process the data thus obtained in accordance with Art. 18 (1, 2, 5) and Art. 19 (1 and 2) of the Law of 18 July 2002 on provision of services via electronic means (Journal of Laws of 2016, No. 0, item 1030 as amended). The aforementioned scope of data shall not be deemed binding to determine the scope of data processed by the Seller. The scope of data processed by the Seller is communicated in Paragraph 5 of the Privacy and Cookies Policy.
Secondly, we may process personal data, if it is deemed necessary for the performance of a contract, where the person referred to by the data is a party to a contract or where it is necessary to take measures before concluding a contract upon request of a person referred to in the data. We process the data thus obtained in accordance with Art. 23 (1) (3) of the Law of 29 August 1997 on protection of personal data (Journal of Laws of 2016, No. 0, item 922 as amended).
Notwithstanding the foregoing, we may also process personal data, if it is deemed necessary to fulfil the legally substantiated objectives implemented by us or by the recipients of data, and the said processing does not violate the rights or freedoms of the person whom they refer to. A legally substantiated objective shall be deemed, in particular, the direct marketing of our products or services, as well as pursuing claims regarding our economic activity. We process the data thus obtained in accordance with Art. 23 (1) (5) and Art. 23 (1) (4) of the Law of 29 August 1997 on personal data protection (Journal of Laws of 2016, No. 0, item 922 as amended).
In other cases, we ask for freely given consent to the processing of personal data. Such consent is effected, in particular, by ticking the relevant "checkbox" while consenting to the processing of personal data. We process the data thus obtained in accordance with Art. 23 (1) (1) of the Law of 29 August 1997 on personal data protection (Journal of Laws of 2016, No. 0, item 922 as amended) or Art. 18 (4) of the Law of 18 July 2002 on provision of services via electronic means (Journal of Laws of 2016, No. 0, item 1030 as amended).
5. PERSONAL DATA SETS, THEIR SCOPES AND OBJECTIVES OF PROCESSING
We process personal data of the Customers in structured sets, which we define in accordance with a purpose of processing thereof. We process the data to the extent necessary to meet the set objectives. The following list contains sets, scopes, as well as objectives of data processing.
|Name of a set||Scope of data processing||Processing purpose|
|Set of personal data of Customers of the Store.||
||Ensuring the use of functionalities of the Store, conclusion and performance of sale contracts concluded with Customers, conducting proceedings resulting from complaints or withdrawals from contracts, provision of commercial, organisational or technical information.|
Sets of personal data of Customers shall be submitted for registration by the General Inspector of Personal Data Protection. Possible applicable exemptions in this respect result in particular from Art. 43 of the Law of 29 August 1997 on personal data protection (Journal of Laws of 2016, No. 0, item 922 as amended).
6. ENTRUSTING AND SHARING PERSONAL DATA
We may entrust personal data of Customers to other entities. Those may include e.g. hosting provider, accounting or legal service, payment operator or another entity with whom we cooperate to ensure adequate provision of services. Entrusting personal data shall always be effected on the basis of a written agreement of data entrustment. The updated list of entities, whom we entrust the data processing is always available to all Customers. To obtain access thereto, it is sufficient to submit a relevant request to us. It can be done e.g. by sending an email message. The legal basis for entrusting personal data shall be Art. 31 of the Law of 29 August 1997 on personal data protection (Journal of Laws of 2016, No. 0, item 922 as amended).
We may commission the processing of data outside the European Economic Area. The right to process personal data, which is in force in those states, may ensure lesser protection than guaranteed by the legal provisions in force in the Republic of Poland. Therefore, if we transfer such data, we particularly try to ensure that the conditions for processing thereof, as set forth herein, be met. A form of such care is the application of standard contractual clauses approved by the European Commission including those in compliance with EU-US Privacy Shield.
We do not share collected data to any third parties with the exception of situations, where it is required by the provisions of universally binding law, i.e. on the basis of request by an authority or court authorised to such acts.
7. CUSTOMER’S RIGHTS
In connection with the processing of personal data, Customers shall be entitled to related rights:
- the right to access one’s own personal data,
- the right to amend one’s own data,
- the right to request that personal data be supplemented, updated, corrected, that processing thereof be temporarily or permanently suspended or that the data be deleted, in the event of their being incomplete, outdated, untrue or in the event of being collected in contravention to the law or of being useless for realisation of the objective for which they were collected,
- the right to withdraw at any time the consent to the processing of personal data for marketing purposes. See how to unsubscribe from our newsletter.
We may make available the system functionalities enabling realisation of those rights. In the event of an intention to use the aforementioned rights, we ask for contact in accordance with the instruction provided in Paragraph 20 of the Privacy and Cookies Policy.
8. SERVER LOGS
Those are internal logs of occurrences in the Store server, automatically registering requests of parties, which are sent, wherever Customers use the Store. System logs contain a party’s request sent by the Customer, IP address, browser type, browser language, date and time of request and at least one "cookie" file, which may uniquely identify the Customer’s browser.
We use the data collected in system logs for an indefinite period, solely for the purposes of Store administration. They are not shared with any third parties, except for the circumstances described herein.
Regarding the use of the Store by Customers, we may automatically collect and record in server logs the technical data regarding the manner of using the service, requests submitted by Customers in connection with the provision of services via electronic means, IP address and technical data on the Store operations in connection with actions carried out by the Customer. Those include information on commencement, ending and the scope of each use of the services provided via electronic means. We may also collect information for its storage locally on Customer’s device, using the mechanism of browser memory.
9. CACHE MEMORY
While providing services to Customers, we may automatically use the cache memory of the browser, application or Customer’s device. The said use involves storing data in the browser memory installed in the Customer’s device. Within the cache memory, it is possible to store intersession data, i.e. between subsequent Customer’s sessions. The purpose of using the cache memory is to accelerate the use of the Store by eliminating situations, where the same data would have to be repeatedly downloaded from the Store, overloading the Customer’s internet connection.
We or third parties through the administered cookies, may use the functionality of geolocalisation consisting in collecting and processing information on Customer’s place of stay. To achieve this, the following data may be processed: IP number, data from GPS sensor, data from Wi-Fi access points or from mobile telephony sites.
11. PIXEL TAG
We or third parties through the administered cookies may use the functionality of pixel tags. Those are elements published in digital content and enabling registration of information e.g. on Customer’s activity on the webpage.
12. COOKIES - INTRODUCTION
While providing services for Customers, we use professional technologies to collect and record information, i.e. cookie files. Those are universally used, small files containing sequences of characters, which are sent and recorded on a terminal device (e.g. computer, laptop, tablet, smart phone) used by the Customer while visiting the Store. The information is sent to the clipboard of the browser in use, which then sends it back on subsequent viewings of the webpage. Cookies contain information necessary for the proper use of the Store. Most often, they contain the name of the webpage from which they originate, duration of storage on a terminal device and a unique identifier. Access to data from cookies may be available also to external entities, listed in Paragraph 16 of the Privacy and Cookies Policy.
13. BASIS FOR PROCESSING COOKIES FILES
We ask the Customers using the services provided via electronic means through the Store, to voluntarily consent to the processing of cookies by storing information or obtaining access to information already stored in their final telecommunications devices.
Granting consent to the processing of cookies takes place, in particular, by using the button containing declaration on consenting to the processing of cookies or acknowledging the conditions. The consent may be withdrawn at any time, free of charge and as described in the section regarding the management of cookies.
We process cookies in pursuance of Art. 173 of the Law of 16 July 2004 Telecommunications law (Journal of Laws of 2016, No. 0, item 1489 as amended).
14. WHAT COOKIES WE USE?
Cookie files may be categorised in pursuance of three methods of classification.
Regarding the purpose of using a cookie file, the following three categories are distinguished:
- necessary files – those files enable proper functioning of the Store and of the functionalities which the Customer may wish to use, e.g. verifying cookies files. Without them being stored in the Customer’s device the use of the Store is not possible,
- functional files – files which enable memorising the settings selected by the Customer and adjusting them to Customer’s needs and preferences, e.g. regarding a selected language, font size, appearance of the webpage. They allow the Seller to improve functionality and performance of the webpage. Without them being recorded on Customer’s device, the use of some functionalities of the Store may be limited,
- business files – including e.g. advertising cookies. They enable the adjustment of advertisements viewed in the Store or elsewhere to the preferences of the Customer. Without them being stored in the Customer’s device, the use of some functionalities of the Store may be limited.
Regarding their validity period, we distinguish two categories of cookies:
- session files – existing until the end of a given Customer’s session,
- permanent files – existing after termination of a session by the Customer.
Regarding the entity administering cookie files, the following tytpes are distinguished:
- Seller’s cookie files,
- cookie files of third parties.
15. SELLER’S COOKIE FILES
Seller’s cookie files ensure recognition of Customer’s device and viewing the webpage of the Store adjusted to Customer’s individual expectations, thereby making the use of its functionalities easier and more pleasant. Thanks to recording those files on Customer’s device, it is possible, e.g. to remember login data, maintain customer session after logging in, remembering selected goods or services or adjusting e.g. content display, language or colour to the Customer’s preferences.
16. COOKIE FILES OF THIRD PARTIES
The Seller may use cookie files used by Google Inc. Amphitheatre Pkwy, Mountain View, CA 94043, USA as part of service provision:
- Google Adwords – those allow to carry out and assess the quality of advertising campaigns, realised through the use of Google Adwords service,
- Google Analytics – those allow to asses the quality of advertising campaigns, realised through the use of Google Adwords service, as well as to study the behaviour and traffic of Customers and preparing traffic statistics,
- Google Maps – those allow to store information on a Customer thus ensuring the use of functionality of maps available as part of Goole Maps service. Google Inc. may trace the localisation of the Customer,
- YouTube – those allow to store information on the Customer thus ensuring the use of functionality of YouTube. Google Inc. may trace the playback of movies by the Customer.
The Seller may use cookie files used by Facebook Inc. 1 Hacker Way, Menlo Park, CA 94025, USA. Those files may be used to connect a user’s accounts in external Facebook social network with the Store’s account, whenever the Seller offers such functionality. Those files may also be used for processing within the Facebook service the Customer’s actions, performed with the use of buttons "Share" or "Like". Processing of those actions may be of public nature.
Using cookie files of third parties shall be conditional upon privacy and cookies policy applied by those entities. We kindly invite whom it may concern to take a look at the principles of processing personal data and privacy policies of entities, which most often and to the greatest extent process our data:
17. MANAGING COOKIE FILES AND OTHER INFORMATION
Most frequently, browser settings allow, by default, installation of cookies and other information on a terminal device. Where the Customer does not consent to storing those files. an appropriate change of settings of an internet browser shall be necessary. It is possible to disable their recording for any connections from a given browser or for a given website as well as their deletion. The manner of managing the files shall depend on the software used. Current principles of file management may be found in the settings of the internet browser in use.
To manage the settings of cookies, select from the following list an internet browser / system and follow the instructions:
Regarding the information on User’s preferences collected by Google advertising network, the User may view and edit information provided by cookie files by means Google Ads Preferences tool.
Information on managing cookie files in a mobile phone may be found in User’s Manual for a given telephone.
Consent to processing cookie files is voluntary. Yet, it must be borne in mind that limitations in use thereof may impair or prevent the use of some of the functionalities of the Store.
18. LINKS TO OTHER WEBPAGES OR SOFTWARE
19. AMENDMENTS TO PRIVACY AND COOKIES POLICY
We reserve the right to amend this privacy and cookies policy. In such a case, we shall publish the updated version in this localisation.
20. CONTACT AND NOTIFICATIONS
We unceasingly do all we can to process personal data of the Customers and cookie files while trying to maintain top standards. Therefore, we have a system in place of immediately responding to situations, which may pose a risk to those standards. In the event of identifying a risk or breach, we kindly ask whom it may concern to immediately contact us using the following data:
Best Sub Europe Sp. z o.o. Sp. K.
We shall be happy to take any feedback. Therefore, in the event of any queries, requests or doubts regarding the processing of personal data or cookie files, we kindly ask for a contact with us.