The following Privacy Policy sets out rules for storing and accessing data on Users' Devices using the Service for the purpose of providing electronic services by the Administrator and Principles of collecting and processing personal data of Users, which were provided by them personally and voluntarily through the tools available on the Site.
The following Privacy Policy is an integral part of the Terms of Use, which sets forth the rules, rights and obligations of Users using the Website.
§1 Definitions
- Service - Internet service "virnalingerie.pl" operating at https://virnalingerie.pl
- External service - websites of partners, service providers or service recipients cooperating with the Administrator
- Service/Data Administrator - The Administrator of the Website and the Data Administrator (hereinafter Administrator) is the company "IRYNA KAMINSKA", conducting business at the address: Krakow ul. Zakopiańska 56/19 , 30-435, with assigned tax identification number (NIP): 6762656618, providing services electronically through the Service
- User - natural person for whom the Administrator provides electronic services through the Service.
- Device - electronic device with software through which the User accesses the Service
- Cookies - text data collected in the form of files placed on the User's Device
- RODO - Regulation (EU) 2016/679 of the European Parliament and of 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)
- Personal information - means information about an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the natural person
- Processing - means an operation or set of operations performed on personal data or sets of personal data in an automated or non-automated manner, such as collecting, recording, organizing, structuring, storing, adapting or modifying, downloading, viewing, using, disclosing by transmission, dissemination or otherwise making available, matching or linking, limiting, deleting or destroying;
- Limitation of processing - means the marking of stored personal data in order to limit its future processing
- Profiling - means any form of automated processing of personal data that involves the use of personal data to evaluate certain personal factors of an individual, in particular to analyze or forecast aspects of that individual's performance, economic situation, health, personal preferences, interests, reliability, behavior, location or movement
- Consent - Consent of the data subject means a voluntary, specific, informed and unequivocal demonstration of will by which the data subject, in the form of a statement or explicit affirmative action, consents to the processing of personal data concerning him or her
- Data protection violations - means a breach of security leading to the accidental or unlawful destruction, loss, modification, unauthorized disclosure of or unauthorized access to personal data transmitted, stored or otherwise processed
- Pseudonymization - means the processing of personal data in such a way that they can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is stored separately and is covered by technical and organizational measures preventing its attribution to an identified or identifiable natural person
- Anonymous - Data anonymization is an irreversible process of data operations that destroys / overwrites "personal data" making it impossible to identify, or link, a particular record to a specific user or individual.
§2 Data Protection Officer
Pursuant to Article 37 of RODO, the Administrator has not appointed a Data Protection Officer.
For matters concerning data processing, including personal data, contact the Administrator directly.
§3 Types of Cookies.
- Internal cookies - files placed and read from the User's Device by the Service's data communications system
- External cookies - files placed and read from the User's Device by the ICT systems of External Services. The scripts of External Services that may place Cookies on User Devices have been knowingly placed on the Website through scripts and services made available and installed on the Website
- Session cookies - files posted and read from the User Device by the Website during a single session of a given Device. When the session ends, the files are deleted from the User Device.
- Persistent cookies - files posted and read from the User Device by the Website until they are manually deleted. The files are not deleted automatically after the end of the Device session unless the configuration of the User Device is set to delete cookies after the end of the Device session.
§4 Data storage security
- Cookie storage and reading mechanisms - The mechanisms for storing, reading and exchanging data between Cookies stored on the User's Device and the Website are implemented through the built-in mechanisms of Internet browsers and do not allow the downloading of other data from the User's Device or data of other websites visited by the User, including personal data or confidential information. It is also virtually impossible to transfer malware to the User Device.
- Internal cookies - The cookies used by the Administrator are safe for the Users' Devices and do not contain scripts, content or information that may compromise the security of personal data or the security of the Device used by the User.
- External cookies - The Administrator makes all possible efforts to verify and select partners of the service in the context of Users' security. The Administrator selects well-known, large partners with global public trust for cooperation. However, it does not have full control over the content of cookies from external partners. The Administrator is not responsible for the security of Cookie files, their content and their use in accordance with the license by the Scripts installed in the service, coming from external Services, as far as the law allows. The list of partners is provided later in the Privacy Policy.
- Cookie control
- The user can at any time, independently change the settings for the storage, deletion and access to data stored cookies by each website
- Information on how to disable cookies in the most popular computer browsers is available on the site: how to disable cookies Or at one of the designated suppliers:
- The User may, at any time, delete any cookies stored to date using the tools of the User's Device through which the User accesses the Website's services.
- Threats on the User's Side - The Administrator uses all possible technical measures to ensure the security of the data placed in cookies. However, it should be noted that ensuring the security of this data depends on both parties including the activities of the User. The Administrator is not responsible for the interception of this data, impersonation of the User's session or its deletion, as a result of the User's conscious or unconscious activity, viruses, Trojan horses and other spyware with which the User's Device may be or has been infected. Users, in order to protect themselves from these threats, should comply with the following recommendations for using the internet.
- Storage of personal data - The Administrator ensures that it makes every effort to ensure that the processed personal data entered voluntarily by the Users are secure, access to them is limited and carried out in accordance with their purpose and the purposes of processing. The Administrator also ensures that it makes every effort to secure the data in its possession against loss, through the use of appropriate physical as well as organizational safeguards.
§5 Purposes for which cookies are used
- Streamline and facilitate access to the Service
- Personalization of the Service for Users
- Keeping statistics (users, number of visits, types of devices, link, etc.).
§6 Purposes of personal data processing
Personal data voluntarily provided by Users are processed for one of the following purposes:
- Realization of electronic services:
- Newsletter services (including sending advertising content with permission)
- Implementation of the service that allows Customers to place orders (make an offer to conclude a contract of sale of Goods) for Goods in the assortment of the Online Store via the Shopping Cart, by using the Order Form (without creating an Account, without logging in)
- Administrator's communication with Users on matters related to the Service and data protection
- To ensure the legitimate interest of the Administrator
Data about Users collected anonymously and automatically is processed for one of the following purposes:
- Keeping statistics
- To ensure the legitimate interest of the Administrator
§7 Cookies of External Services
The Administrator on the Website uses javascript and web components of partners that may place their own cookies on the User's Device. Remember that in your browser settings you can decide for yourself about the allowed cookies that can be used by particular websites. Below is a list of partners or their services implemented on the Website that may place cookies:
- Cookie Management Services:
- CookieYes
Services provided by third parties are beyond the control of the Administrator. These entities may change their terms of service, privacy policies, purpose of data processing and use of cookies at any time.
§8 Types of data collected
The Service collects data about Users. Part of the data is collected automatically and anonymously, and part of the data is personal data voluntarily provided by Users when signing up for particular services offered by the Service.
Anonymous data collected automatically:
- IP address
- Browser type
- Screen resolution
- Approximate location
- Openable subpages of the website
- Time spent on the relevant subpage of the website
- Type of operating system
- Previous subpage address
- Address of the referring page
- Browser language
- Internet connection speed
- Internet service provider
Data collected when ordering goods/executing sales contracts:
- Name
- Address of residence
- E-mail address
- Phone number
- IP address (collected automatically)
- Tax ID number
Data collected when signing up for the Newsletter service
- Name
- E-mail address
Part of the data (without identifying information) may be stored in cookies. Part of the data (without identifying data) may be transferred to a statistical service provider.
§9 Access to personal data by third parties
As a rule, the only recipient of personal data provided by Users is the Administrator. Data collected as part of the services provided are not transferred or resold to third parties.
Access to the data (most often on the basis of a Data Processing Entrustment Agreement) may have entities, responsible for maintaining the infrastructure and services necessary to run the service, i.e.:
- Hosting companies, providing hosting or related services to the Administrator
- Companies through which the Newsletter service is provided
- Companies that act as intermediaries in online payments for goods or services offered on the Website (if you make a purchase transaction on the Website)
- Companies responsible for the Administrator's bookkeeping (in case of purchase transactions in the Service)
- Companies responsible for the delivery of physical products to the User (postal / courier services in case of purchase transactions on the Website)
Entrustment of personal data processing - Newsletter
The Administrator in order to provide the Newsletter service does not use the services of third parties.
Entrustment of personal data processing - Hosting, VPS or Dedicated Server Services
In order to run the site, the Administrator uses a third-party hosting provider, VPS or Dedicated Servers -. Host4Biz sp. z o.o. All data collected and processed in the service is stored and processed in the infrastructure of the service provider located in Poland. There is a possibility of access to the data as a result of maintenance work carried out by the service provider's staff. Access to such data is governed by an agreement between the Administrator and the Service Provider.
Data processing for online payments
In the case of online payment processing, all payment data are transferred directly by the User to the payment processor - the payment processor.PayPro S.A. The selected data necessary to complete the transaction are then transferred by this entity to the Administrator. The transfer of data is governed by an agreement between the Administrator and the Service Provider.
Transfer of personal data - Accounting Services
If a transaction is concluded, part of the personal data of individuals or the data of individuals engaged in business activities is transferred to the entity providing accounting services to the Administrator IFIRMA SA. The transfer of this data is governed by the Law .... and the contract between the Administrator and the Service Provider.
Transfer of personal data - Courier Services
In the case of a transaction that requires the transfer of the subject matter of the transaction through the mail or by courier, part of the personal data of individuals or data of individuals conducting business is transferred to the entity providing postal/courier services to the Administrator, selected by the User. The transfer of this data is governed by an agreement between the Administrator and the Service Provider.
§10 Method of processing personal data
Personal data provided voluntarily by Users:
- Personal data will not be transferred outside the European Union, unless published as a result of an individual action by the User (e.g., entering a comment or entry), which will make the data available to any visitor to the site.
- Personal data will not be used for automated decision-making (profiling).
- Personal data will not be resold to third parties.
Anonymous data (no personal information) collected automatically:
- Anonymous data (without personal information) will be transferred outside the European Union.
- Anonymous data (without personal data) will not be used for automated decision-making (profiling).
- Anonymous data (without personal information) will not be resold to third parties.
§11 Legal grounds for processing personal data
The Service collects and processes Users' data on the basis of:
- Regulation (EU) 2016/679 of the European Parliament and of 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)
- Article 6(1)(a)
the data subject has consented to the processing of his/her personal data for one or more specified purposes - Article 6(1)(b)
processing is necessary for the performance of a contract to which the data subject is a party, or to take action at the request of the data subject prior to entering into a contract - Article 6(1)(f)
processing is necessary for the purposes of legitimate interests pursued by the controller or by a third party
- Article 6(1)(a)
- Act of May 10, 2018 on the protection of personal data (Journal of Laws 2018 item 1000).
- Law of July 16, 2004. Telecommunications law (Dz.U. 2004 No. 171 item 1800)
- Act of February 4, 1994 on Copyright and Related Rights (Journal of Laws 1994 No. 24 item 83)
§12 Period of personal data processing
Personal data provided voluntarily by Users:
As a rule, the indicated personal data are kept only for the period of providing the Service within the Service by the Administrator. They are deleted or anonymized up to 14 days after the termination of services (e.g. deletion of a registered user account, unsubscribing from the Newsletter list, etc.).
The exception is the situation that requires securing the legitimate purposes of further processing of such data by the Administrator.
Anonymous data (no personal information) collected automatically:
Anonymous statistical data, which do not constitute personal data, are stored by the Administrator for the purpose of service statistics for an indefinite period of time
§13 Users' rights related to the processing of personal data
The Service collects and processes Users' data on the basis of:
- Right of access to personal data
Users have the right to obtain access to their personal data, exercised upon request submitted to the Administrator - Right to rectify personal data
Users have the right to request the Administrator to promptly rectify personal data that is incorrect and/or to complete incomplete personal data, exercised upon request submitted to the Administrator - The right to delete personal data
Users have the right to demand from the Administrator immediate deletion of their personal data, realized upon a request submitted to the Administrator In the case of user accounts, deletion of data consists in anonymization of data enabling identification of the User. The Administrator reserves the right to withhold the execution of a request for deletion of data in order to protect the legitimate interest of the Administrator (e.g. when the User has violated the Terms of Use or the data was obtained as a result of ongoing correspondence).
In the case of the Newsletter service, the User has the option of deleting his/her personal data himself/herself by using the link provided in each e-mail message sent. - The right to restrict the processing of personal data
Users have the right to restrict the processing of personal data in the cases indicated in Article 18 of the RODO, including questioning the correctness of personal data, exercised upon request submitted to the Administrator - Right to portability of personal data
Users have the right to obtain from the Administrator, personal data concerning the User in a structured, commonly used machine-readable format, executed upon request submitted to the Administrator - The right to object to the processing of personal data
Users have the right to object to the processing of their personal data in the cases specified in Article 21 of the RODO, exercised upon request submitted to the Administrator - The right to file a complaint
Users have the right to lodge a complaint with the data protection supervisory authority.
§14 Contact to the Administrator
The Administrator can be contacted in one of the following ways
- E-mail address - sklep@virnalingerie.pl
§15 Service Requirements
- Restricting the storage of and access to Cookies on the User's Device may result in the malfunction of some features of the Website.
- The Administrator shall not be held responsible for malfunctioning functions of the Website in case the User restricts in any way the ability to save and read Cookie files.
§16 Changes to Privacy Policy
- The Administrator reserves the right to change this Privacy Policy at any time without notifying Users regarding the use and application of anonymized data or the use of cookies.
- The Administrator reserves the right to amend this Privacy Policy at any time with regard to the processing of Personal Data, of which it will inform Users with user accounts or subscribed to the newsletter service, via e-mail within 7 days of the change in records. Continued use of the services implies familiarization with and acceptance of the introduced changes to the Privacy Policy. In case the User does not agree with the introduced changes, he/she is obliged to delete his/her account from the Service or unsubscribe from the Newsletter service.
- Changes made to the Privacy Policy will be published on this subpage of the Website.
- The changes made shall take effect upon publication.