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Privacy policy

When you contact us, use the Website, the Electronic Services we offer, we process your Personal Data.

We respect your privacy and strive, in such cases, to apply best practices in the area of processing your Personal Data – especially in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC, also known as the General Data Protection Regulation (GDPR).

 

This Privacy and Cookies Policy explains who we are, how we process your Personal Data, which cookies we use, your rights in this regard and how you can contact us if necessary.

 

The Privacy and Cookies Policy has been created for informational purposes only, which means that it does not give rise to legal obligations either for you or for the Vendor (it does not constitute a contract). Consequently, we reserve the right to change and improve the Privacy and Cookies Policy from time to time.

 

Table of contents

I. Glossary – basic concepts.
II. Who is the controller of your personal data?
III. What Personal Data do we collect, what is the purpose, duration and legal basis of its processing?

VISITS TO THE SITE
REGISTRATION ON THE SITE (ACCOUNT)
CONCLUSION OF SALES CONTRACTS
NEWSLETTER
CONTACT WITH US

IV. Who has access to your Personal Data?
V. Your rights in relation to the processing of your Personal Data
VI. What are “cookies” and other similar technological solutions? How and for what purpose do we use them?

I. Glossary – basic terms.

Personal Data – all information relating to you that we process. For example: name, surname, email address, telephone number, etc.

Processing – any activity performed on Personal Data. For example: collecting, storing, updating, deleting data.

All capitalized words/terms used in the Privacy Policy and Cookies, not defined above, shall be understood in the meaning ascribed to them by the Terms and Conditions, unless a different meaning is clear from the context in which they are used.

II. Who is the controller of your personal data?

The controller of your personal data is Lupin Hill e-mail address: info@all-season.pl

III. What Personal Data do we collect, what is the purpose, duration and legal basis of the processing?

 

1.VISITS TO THE WEBSITE 

When you visit the Website, we may use cookies and other related technological solutions (for details, please refer to point VI of the Privacy and Cookies Policy), which allows us to maintain the proper functioning of the Website, as well as to analyse information about your activity on the Website. We process this data to improve the quality of the services we offer and to improve the functioning of the Website. It may also be the case that cookies (or similar) also help us to tailor the content available through the Service to your interests (profiling). We may use some cookies for marketing purposes, both on the Service and on the websites of our business partners.

The legal basis for the use of cookies and similar technologies is generally your consent.

The basis for the processing of data collected using cookie technology, on the other hand, is our or a so-called “third party’s” legitimate interest (Article 6(1)(f) RODO – among other things, the need to ensure the highest quality of the content presented and sometimes also the marketing of our or our partners’ products and services, in which case the partners are not involved in the processing of your data. To the extent that also our partners may have direct access to this information – the legal basis for such processing is your freely given consent (Article 6(1)(a) RODO).

We process Personal Data on the basis of your consent at most until you revoke it. Personal Data processed on the basis of our legitimate interest may be stored until you object to the processing, except where, despite your objection, we conclude that there are compelling legitimate grounds for the processing which override your interests, rights and freedoms, or grounds for establishing, pursuing or defending claims.

The above does not apply where the use of cookies and similar is necessary for the proper operation of the Service (to provide you with the electronically provided service), where we rely on the law and the necessity of the processing for the performance of the Service Agreement, respectively (Article 6(1)(b) RODO). Your Personal Data is then processed for the period necessary for these purposes.

Information about the recipients of your Personal Data, including the possible transfer of your Personal Data to third countries (outside the European Economic Area), is detailed in section IV below. 

The rights you have in relation to the processing of your Personal Data are detailed in section VI below.

2. REGISTRATION ON THE SERVICE (ACCOUNT) 

In order to create an Account on our Service, we will require you to provide certain Personal Data, e.g. name, surname, email address. The provision of all information is voluntary, however, some data is necessary for the conclusion of a Service Agreement and failure to provide such data may mean that the conclusion of such agreement will not be possible.

Personal Data that is not required may help us in terms of improving our Service. We may also use them for statistical purposes.

The purpose, as well as the legal basis for the processing, is the conclusion and proper performance of the Service Agreement (Article 6(1)(b) RODO) – e.g. the creation of an Account for you and the storage of your Order history within the Account.

Your data may also be processed for the purpose of marketing activities, e.g. presenting you with advertisements and offers (discounts), also tailored to your interests based on profiling (legal basis for these activities: Article 6(1)(f) RODO, i.e. the legitimate interest of the Administrator or a third party (the Administrator’s own or partners’ marketing).

We may also process your Personal Data for the purposes of detecting and preventing any privacy risks, fraud or other bad faith activity, and for the purposes of establishing, investigating and pursuing claims that may arise in the relationship between you and the Administrator. In this case, the legal basis for the processing is our legitimate interest (Article 6(1)(f) of the DPA).

We process your Personal Data for the duration of the Service Agreement (with the understanding that, for their greater protection, they may be deleted two years after your last activity on the Website). This period may be extended as appropriate in connection with possible claims (within the limitation period under the law, primarily the Civil Code) or legal proceedings – for the duration and settlement thereof. In any case, the longer retention period for Personal Data shall apply.

Personal Data processed on the basis of our legitimate interest may be processed until you object to the processing, except where, despite your objection, we conclude that there are compelling legitimate grounds for processing overriding your interests, rights and freedoms, or grounds for establishing, pursuing or defending claims.

Information about the recipients of your Personal Data, including the possible transfer of your Personal Data to third countries (outside the European Economic Area), is detailed in section IV below. 

The rights you have in relation to the processing of your Personal Data are detailed in section VI below.

3. CONCLUSION OF SALES CONTRACTS 

When you make purchases on our Website, we process information relating to the placement of Orders and the execution of Sales Agreements. In order to conclude and perform a Sales Agreement, we will require you to provide certain Personal Data, e.g. name, surname, email address, mailing address, billing details. The provision of all information is voluntary, however, some data is necessary for the conclusion of a Sales Agreement and failure to provide such data may mean that the conclusion of such an agreement will not be possible.

Personal Data that is not required may help us in terms of improving our Service. We may also use them for statistical purposes.

The purpose, as well as the legal basis for the processing is the conclusion and proper performance of the Sales Contract (Art. 6(1)(b) RODO) – e.g. the delivery of the Products you have ordered. 

Your data may also be processed for the purpose of marketing activities, e.g. presenting you with advertisements and offers (discounts), also tailored to your interests based on profiling (legal basis for these activities: Article 6(1)(f) RODO, i.e. the legitimate interest of the Administrator or a third party (the Administrator’s own marketing or partners).

We may also process part of your Personal Data in order to consider and assert claims, as well as to comply with legal obligations arising from relevant legislation, e.g. tax and accounting obligations – the legal basis for the processing is, respectively, our legitimate interest (Article 6(1)(f) RODO) or the need to comply with a legal obligation (Article 6(1)(c) RODO).

If you have concluded a Sales Contract with us, we process your Personal Data for the period necessary for the performance of the Sales Contract and usually for a maximum of 7 subsequent years after the conclusion of the Sales Contract, as determined in particular by tax legislation.

The processing periods described above may be extended accordingly in connection with possible claims, including legal proceedings – for the duration and settlement thereof, and if the law obliges us in certain cases to process the type of data in question for a longer period. In any case, the longer retention period for Personal Data will apply.

Personal Data processed on the basis of our legitimate interest may be retained until you object to the processing, except where, despite your objection, we conclude that there are compelling legitimate grounds for the processing which override your interests, rights and freedoms, or grounds for establishing, pursuing or defending claims.

Information about the recipients of your Personal Data, including the possible transfer of your Personal Data to third countries (outside the European Economic Area), is detailed in section IV below. 

The rights you have in relation to the processing of your Personal Data are detailed in section VI below.

4 NEWSLETTER

We may send you commercial information about us and our Products (or our partners) through the communication channel of your choice, but only with your prior consent, also tailored to your interests based on profiling. The legal basis for processing your Personal Data for this purpose is our or our partners’ legitimate interest (Article 6(1)(f) RODO) – our or a third party’s marketing purposes. 

The provision of Personal Data is voluntary, but necessary to subscribe to the Newsletter. 

We may also process your Personal Data for the purpose of handling and investigating claims – the legal basis for the processing is our legitimate interest, respectively (Art. 6(1)(f) RODO).

We may process your Personal Data for the period in which it is necessary for our marketing activities, unless you object to its processing, the longer period is due to its retention in case of possible claims for the limitation period set by law, in particular the Civil Code, or for the duration and settlement of legal proceedings. In any case, the longer period of storage of Personal Data is decisive.

Information about the recipients of your Personal Data, including the possible transfer of your Personal Data to third countries (outside the European Economic Area), is detailed in section IV below. 

The rights you have in relation to the processing of your Personal Data are detailed in section VI below.

5. CONTACTING US

When you contact us, e.g. using email, accessible forms, social media, etc., examples of Personal Data that we may process are: Personal Data that identifies you (e.g. email address, IP number, etc.), contact metadata (e.g. date of contact, duration of our conversation), and the content of our communication (e.g. content of emails). Your Personal Data is processed for the purpose of answering your query, improving our communication, enhancing our customer service, as well as for marketing purposes. The purpose of the processing depends on the purpose of our communication, hence sometimes your Personal Data will be used to enter into a relevant contract with you or, if we already have a contractual relationship, to provide you with appropriate care within the framework of our cooperation (e.g. handling your complaint).

In such cases, the legal basis for the processing depends on the context of the communication. If you are only contacting us to obtain general information, e.g. regarding the Service, we will process your Personal Data based on our legitimate interest (derived from the purposes mentioned above; Article 6(1)(f) RODO). However, where your enquiry leads to the conclusion of a Sales Contract, the relevant legal basis for the processing will be Article 6(1)(b) RODO – taking action at the request of the data subject prior to the conclusion of a contract. If we already have a contract in place and you contact us about the performance of the contract, the relevant legal basis for our actions will be Article 6(1)(b) RODO – necessity for the performance of the contract.

We may also process your Personal Data for the purpose of handling and investigating claims – the legal basis for the processing is, accordingly, our legitimate interest (Article 6(1)(f) RODO).

The provision of Personal Data is voluntary, but necessary in order to communicate with us effectively. 

If your Personal Data has only been collected in connection with our current communications, we may process it, depending on the category of the particular information, for a period ranging from a few days to several months (more specific enquiries and conversations that may be relevant to our future contact).

Personal Data processed on the basis of our legitimate interest may be retained until you object to its processing, except where, despite your objection, we conclude that there are compelling legitimate grounds for processing overriding your interests, rights and freedoms, or grounds for establishing, pursuing or defending claims.

The rules for the protection and use of Personal Data by social media you may use when contacting us are described in their privacy policies. For example, information on the processing of Personal Data by Facebook can be found at: https://www.facebook.com/policy.php.

Information about the recipients of your Personal Data, including the possible transfer of your Personal Data to third countries (outside the European Economic Area), is detailed in section IV below. 

The rights you have in relation to the processing of your Personal Data are detailed in section VI below.

IV. Who has access to your Personal Data?

Access to your Personal Data is only granted to entities that support us in the operation of the Service on the basis of relevant contracts, e.g. entities that provide IT services or tools to enable our communications, marketing campaigns, our advisors, including legal advisors, entities that provide shipping, accounting and online payment services.

All of these entities only have access to information necessary for their operations.

Some of the entities providing solutions to us may be based outside the European Economic Area (EEA). Whenever we transfer data outside the EEA, we apply the required security measures, including, for example, standard data protection clauses adopted under a European Commission decision, with appropriate safeguards in place. You can obtain a copy of the safeguards we apply to the transfer of personal data to a country outside the EEA by contacting us.

V. Your rights in relation to the processing of your personal data

For the efficient exercise of your rights, please address any requests to the email address indicated in the glossary by writing “RODO request” in the title and specifying in the body which right you wish to exercise. The instructions given in the preceding sentence are only a recommendation and not a requirement. Making a request by other means does not lead to the loss of the rights listed below.

At any time you have the right to:

  1. to have access to your Personal Data (including, for example, to receive information as to which Personal Data are being processed or a copy thereof);
    request rectification and restriction of processing (e.g. where Personal Data is inaccurate) or erasure of Personal Data (e.g. where it has been unlawfully processed);
    to transfer Personal Data that you have provided to the Controller and which is processed by automated means and the processing is based on consent or on contract, e.g. to another controller;
    to withdraw any consent given to the Administrator at any time, whereby the withdrawal of consent does not affect the processing carried out by the Administrator lawfully before the withdrawal of consent;
    object to the processing of Personal Data carried out for the purposes of the legitimate interests of the Administrator or a third party (where there are no other valid legitimate grounds for processing overriding your interests). If your Personal Data is processed for direct marketing purposes, you have the right to object at any time to the processing of your Personal Data for such marketing, including profiling, to the extent that the processing is related to such direct marketing, in which case your Personal Data must no longer be processed for such purposes.  
    lodge a complaint with the President of the Personal Data Protection Authority (a detailed description of the procedure for lodging a complaint is available at: https://uodo.gov.pl/pl/83/155). Of course, if you wish to make comments on the way we operate, we encourage you to contact us in advance.

VI. What are cookies and other similar technologies? How and for what purpose do we use them?

Cookies are small data files that are stored on your device when you visit the Website and, for example, store information about your use of the Website. We use cookies and other technological solutions to recognise you as a returning User, to improve the quality of our service and to collect statistical data, as well as for marketing purposes. We also process them to analyse the popularity and effectiveness of our offers.

The cookie technology (or similar functionality) we use collects information about each visitor to the Website. Please note that the information below applies to individuals who use the Service, whether they have placed an Order or have an Account.

The information collected in cookies does not always constitute Personal Data within the meaning of the RODO. However, some information, depending on its content and how it is used, may be linked to a specific person (attribution of certain behaviour to a specific person, e.g. by linking it to the data provided when registering an Account with the Service) and thus be considered Personal Data.

You may, of course, change the way you use cookies, including blocking them completely or deleting them through your browser settings. However, you must bear in mind that this type of operation may prevent or significantly hinder the proper functioning of our Website, if only by significantly slowing down its operation, which is why we recommend that you do not disable their use in your browser.

We always provide you with information explaining precisely which cookies we use and for which purposes, when you first visit our Website.

We use two types of cookies on the Website: session cookies, which remain stored on your computer or mobile device until you log off from the Website or switch off your software (web browser), and permanent cookies, which remain on your device for the time specified in the parameters of the cookies or until they are manually deleted in your web browser.

Depending on the case, we may use the following types of cookies in particular:

technical – necessary for the proper functioning of the Website and the functionalities available on the Website; these cookies are not used to track visitors to the Website;
analytical/performance cookies – used to analyse your behaviour on the Website, for statistical and analytical purposes; they help us to achieve our legitimate aims of improving the way our website works; for example, by ensuring that users can easily find what they are looking for;
marketing – used to analyse your behaviour; provide you with personally identifiable information, including for marketing purposes on third party websites; we will use this information, taking into account your choices and preferences, to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

 

List of cookies used on the Website:

Type:

Description

Expiry time

cookielawinfo_checkbox_ analyticsThis cookie is set by the RODO Cookie Consent plugin. The cookie is used to store the user’s consent to cookies in the “Analytics” category. 11 months
cookielawinfo-checkbox-functionalThe cookie is set by the RODO cookie consent to record the user’s consent to cookies in the “Functional” category. 11 months
cookielawinfo-checkbox-necessaryThis cookie is set by the RODO Cookie Consent plug-in. The cookies are used to store the user’s consent to cookies in the “Necessary” category. 11 months
 cookielawinfo-checkbox-othersThis cookie is set by the RODO Cookie Consent plug-in. The cookie is used to store the user’s cookie consent under the category ‘Other. 11 months
cookielawinfo-checkbox-performance This cookie is set by the RODO Cookie Consent plug-in. The cookie is used to store the user’s cookie consent in the “Performance” category. 11 months

It may happen that we collaborate with other companies for their marketing (advertising) activities. For the purposes of such cooperation, your browser or other software installed on your device may also store cookies from entities conducting such marketing activities, which may become the controller of your Personal Data (these are so-called third party cookies). The cookies sent by these entities are intended to ensure that you are only presented with advertisements that match your individual interests and needs. We believe that displaying personalised advertising may be more attractive to you than advertising that is unrelated to your needs. Without these cookies, this would not be possible as it is the companies working with us that provide advertising content for you.

We may use the following entities or services of entities that use cookies on the Service:

  1. Google AdWords 
  2. Google Analytics 

The service relates to Google LLC or an affiliated entity (these are entities belonging to the Google group of companies, among others, companies providing services to consumers within the European Union, i.e. Google Ireland Limited, Google Commerce Ltd, Google Payment Corp and Google Dialer Inc).
DoubleClick
Facebook, Inc., Facebook Ireland Limited or their affiliates
Opineo
Trustedshop

The aforementioned entities, in connection with the use of their own cookies on the Website, may become controllers of your Personal Data. For more information on their cookies, please refer to their privacy policies.

Last update of the Privacy and Cookies Policy: 14 March 2022.