PRIVACY POLICY OF THE SENOA.PL ONLINE STORE

1.GENERAL PROVISIONS

1.1. This privacy policy of the Online Store is for informational purposes, which means it does not create obligations for Service Users or Customers of the Online Store. The privacy policy primarily contains rules regarding the processing of personal data by the Administrator in the Online Store, including the bases, purposes, and period of personal data processing, as well as the rights of data subjects, and information regarding the use of Cookies and analytical tools in the Online Store.

1.2. The administrator of personal data collected via the Online Store are the partners jointly conducting business activity under a civil partnership agreement named V&K COSMETIC KRZYSZTOF MROWIEC, VIOLETTA MROWIEC SPÓŁKA CYWILNA (address of business activity and delivery address: ul. Rolnicza 38E, 34-300 Żywiec), civil partnership NIP: 5532512335, civil partnership REGON: 243202379, email address: zamowienia@senoa.pl and phone number: +48 882 771 681, i.e., (1) Krzysztof Mrowiec conducting business activity under the name KRZYSZTOF MROWIEC partner of the V&K COSMETIC civil partnership (address of business activity: ul. Rolnicza 38E, 34-300 Żywiec) entered into the Central Register and Information on Economic Activity of the Republic of Poland maintained by the minister responsible for economy, NIP: 5530003411, REGON: 070524183, and (2) Violetta Mrowiec conducting business activity under the name VIOLETTA MROWIEC partner of the V&K COSMETIC s.c. civil partnership (address of business activity: ul. Rolnicza 38E, 34-300 Żywiec) entered into the Central Register and Information on Economic Activity of the Republic of Poland maintained by the minister responsible for economy, NIP: 5530016158, REGON: 072147939 – hereinafter referred to as the “Administrator” and simultaneously being 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 in accordance 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”. The official text of the GDPR Regulation: http://eur-lex.europa.eu/legal-content/PL/TXT/?uri=CELEX%3A32016R0679

1.4. The use of the Online Store, including making purchases, is voluntary. Similarly, the provision of personal data by the Service User or Customer using the Online Store is voluntary, with two exceptions: (1) entering into agreements with the Administrator – failure to provide personal data necessary for the conclusion and performance of a Sales Agreement or an Electronic Service agreement with the Administrator, in cases and to the extent indicated on the Online Store’s website and in the Online Store’s Terms and Conditions and this privacy policy, results in the inability to conclude such an agreement. In such a case, providing personal data is a contractual requirement, and if the data subject wishes to conclude a given agreement with the Administrator, they are obliged to provide the required data. The scope of data required for concluding an agreement is always indicated beforehand on the Online Store’s website and in the Online Store’s Terms and Conditions; (2) Administrator’s legal obligations – providing personal data is a statutory requirement resulting from generally applicable legal provisions imposing on the Administrator the obligation to process personal data (e.g., processing data for maintaining tax books), and failure to provide them will prevent the Administrator from fulfilling these obligations.

1.5. The Administrator exercises particular diligence to protect the interests of data subjects whose personal data are processed by him, and in particular is responsible for and ensures that the data collected by him are: (1) processed lawfully; (2) collected for specified, legitimate purposes and not further processed in a manner incompatible with those purposes; (3) factually correct and adequate in relation to the purposes for which they are processed; (4) stored in a form enabling identification of data subjects for no longer than is necessary for the purposes for which the data are processed; and (5) processed in a manner that ensures appropriate security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.

1.6. Considering the nature, scope, context, and purposes of processing, and the risks of varying likelihood and severity for the rights and freedoms of natural persons, the Administrator implements appropriate technical and organizational measures to ensure and be able to demonstrate that processing is performed in accordance with the GDPR Regulation. These measures are reviewed and updated as necessary. The Administrator applies technical measures to prevent unauthorized persons from obtaining and modifying personal data transmitted electronically.

1.7. All words, phrases, and acronyms appearing in this privacy policy and starting with a capital letter (e.g., Seller, Online Store, Electronic Service) should be understood in accordance with their definition contained in the Online Store’s Terms and Conditions available on the Online Store’s pages.

2. BASES FOR DATA PROCESSING

2.1. The Administrator is authorized to process personal data in cases where – 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 in order 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. The processing of personal data by the Administrator always requires the existence of at least one of the bases indicated in point 2.1 of the privacy policy. Specific bases for processing personal data of Service Users and Customers of the Online Store by the Administrator are indicated in the next point of the privacy policy – in relation to the given purpose of personal data processing by the Administrator.

3. PURPOSE, BASIS, AND PERIOD OF DATA PROCESSING IN THE ONLINE STORE

3.1. The purpose, basis, period, and recipients of personal data processed by the Administrator always result from actions taken by a given Service User or Customer in the Online Store or by the Administrator. For example, if a Customer decides to make purchases 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 a Sales Agreement or an Electronic Service agreement or taking steps at the request of the data subject prior to entering into the aforementioned agreements	Article 6(1)(b) of the GDPR Regulation (performance of a contract) – processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract	Data is stored for the period necessary for the performance, termination, or other expiry of the concluded Sales Agreement or Electronic Service agreement.
Marketing of Administrator’s goods and services (e.g., sending commercial information, including direct marketing, using telecommunications terminal equipment, such as email and phone, or automatic calling systems)	Article 6(1)(f) of the GDPR Regulation (legitimate interest of the administrator) – processing is necessary for the purposes of the legitimate interests pursued by the Administrator, which include direct marketing – consisting of protecting the Administrator’s interests and good image, its Online Store, and striving to sell Products – for example, in connection with the data subject’s prior consent (e.g., when subscribing to a Newsletter) to receive commercial information using telecommunications terminal equipment, such as email or phone, depending on the scope of the granted consent	Data is stored for the period of the Administrator’s legitimate interest, but no longer than the statute of limitations for the Administrator’s claims against the data subject arising from the Administrator’s business activity. The statute of limitations is determined by law, in particular the Civil Code (the basic limitation period for claims related to business activity is three years, and for a Sales Agreement, two years). The Administrator cannot process data for direct marketing if the data subject has effectively objected to it. Additionally, if the basis for processing is consent to send commercial information, including direct marketing, using telecommunications terminal equipment or automatic calling systems, data is stored until the data subject withdraws consent for further processing of their data for this purpose, but without affecting the lawfulness of processing carried out on the basis of consent before its withdrawal.
Customer’s expression of opinion on a concluded Sales Agreement	Article 6(1)(a) of the GDPR Regulation (consent) – the data subject has given consent to the processing of their personal data for the purpose of expressing an opinion	Data is stored until the data subject withdraws consent for further processing of their data for this purpose.
Maintaining tax books	Article 6(1)(c) of the GDPR Regulation (legal obligation) in conjunction with Article 86 § 1 of the Tax Ordinance, i.e., of January 17, 2017 (Journal of Laws of 2017, item 201 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 for the Administrator to maintain tax books (until the expiration of the tax liability’s statute of limitations, unless tax laws state otherwise).
Establishing, pursuing, or defending claims that the Administrator may raise or that may be raised against the Administrator	Article 6(1)(f) of the GDPR Regulation (legitimate interest of the administrator) – processing is necessary for the purposes of the legitimate interests pursued by the Administrator – consisting of establishing, pursuing, or defending claims that the Administrator may raise or that may be raised against the Administrator	Data is stored for the period of the Administrator’s legitimate interest, but no longer than the statute of limitations for claims that may be raised against the Administrator (the basic limitation period for claims against the Administrator is six years).
Using the Online Store website and ensuring its proper functioning	Article 6(1)(f) of the GDPR Regulation (legitimate interest of the administrator) – processing is necessary for the purposes of the legitimate interests pursued by the Administrator – consisting of operating and maintaining the Online Store website	Data is stored for the period of the Administrator’s legitimate interest, but no longer than the statute of limitations for the Administrator’s claims against the data subject arising from the Administrator’s business activity. The statute of limitations is determined by law, in particular the Civil Code (the basic limitation period for claims related to business activity is three years, and for a Sales Agreement, two years).
Conducting statistics and analyzing traffic in the Online Store	Article 6(1)(f) of the GDPR Regulation (legitimate interest of the administrator) – processing is necessary for the purposes of the legitimate interests pursued by the Administrator – consisting of conducting statistics and analyzing traffic in the Online Store to improve the Online Store’s functioning and increase Product sales	Data is stored for the period of the Administrator’s legitimate interest, but no longer than the statute of limitations for the Administrator’s claims against the data subject arising from the Administrator’s business activity. The statute of limitations is determined by law, in particular the Civil Code (the basic limitation period for claims related to business activity is three years, and for a 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 Sales Agreements, it is necessary for the Administrator to use the services of external entities (such as software providers, couriers, or payment processors). The Administrator only uses the services of such processors who provide sufficient guarantees of implementing appropriate technical and organizational measures to ensure 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, it will be to a country providing an adequate level of protection – consistent with the GDPR Regulation, and in the case of other countries, that the transfer will take place on the basis of 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 if and to the extent necessary to achieve a given data processing purpose consistent 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 a given personal data processing purpose and only to the extent necessary to achieve it. For example, if a Customer uses personal pickup, their data will not be transferred to a carrier cooperating with the Administrator.

4.4. Personal data of Service Users and Customers of the Online Store may be transferred to the following recipients or categories of recipients:

4.4.1. carriers / freight forwarders / courier brokers / warehouse and/or shipping process operators – in the case of a Customer who uses postal or courier delivery for a Product 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 from an external warehouse – to the entity operating the warehouse and/or shipping process – to the extent necessary to deliver the Product to the Customer.

4.4.2. electronic or credit card payment processors – in the case of a Customer who uses electronic or credit card payment methods in the Online Store, the Administrator provides the collected personal data of the Customer to the selected entity processing these payments in the Online Store on behalf of the Administrator to the extent necessary to process the payment made by the Customer.

4.4.3. lending entities – in the case of a Customer who uses installment payment or deferred payment methods in the Online Store, the Administrator provides the collected personal data of the Customer to the selected lender or financing entity processing these payments in the Online Store on behalf of the Administrator to the extent necessary to process the payment made by the Customer.

4.4.4. survey system providers – in the case of a Customer who has agreed to provide feedback on a concluded Sales Agreement, the Administrator provides the collected personal data of the Customer to the selected entity providing the 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 survey system.

4.4.5. service providers supplying the Administrator with technical, IT, and organizational solutions, enabling the Administrator to conduct business activity, including the Online Store and Electronic Services provided through it (in particular, providers of computer software for operating the Online Store, email and hosting providers, and software providers for company management and technical support to the Administrator) – the Administrator provides the collected personal data of the Customer to the selected provider acting on its behalf only if and to the extent necessary to achieve a given data processing purpose consistent with this privacy policy.

4.4.6. accounting, legal, and advisory service providers offering the Administrator accounting, legal, or advisory support (in particular, accounting firms, law firms, or debt collection agencies) – the Administrator provides the collected personal data of the Customer to the selected provider acting on its behalf only if and to the extent necessary to achieve a given data processing purpose consistent with this privacy policy.

4.4.7. providers of social plugins, scripts, and other similar tools placed on the Online Store’s website that enable the browser of a visitor to the Online Store’s website to download content from the providers of the aforementioned plugins (e.g., logging in using social media login credentials) and to transfer the personal data of the visitor to these providers for this purpose, including:

4.4.7.1.Meta Platforms Ireland Ltd. – The Administrator may use social plugins from Facebook or Instagram (e.g., “Like” button, “Share” button, logging in using Facebook login credentials, etc.) on the Online Store’s website and, in connection with this, collects and shares personal data of Service Users using the Online Store’s website with Meta Platforms Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland) to the extent and in accordance with the privacy principles available here: https://www.facebook.com/about/privacy/ (this data includes information about activities on the Online Store’s website – including information about the device, visited websites, purchases, displayed ads, and how services are used – regardless of whether the person has a Facebook or Instagram account and whether they are logged in to it).

4.4.7.2.Google Ireland Limited – The Administrator may use Google and YouTube service plugins on the Online Store’s website (e.g., logging in using Google login credentials, YouTube video players) and, in connection with this, collects and shares personal data of Service Users using the Online Store’s website with Google Ireland Ltd. (Gordon House, Barrow Street, Dublin 4, Ireland) to the extent and in accordance with the privacy principles available here: https://policies.google.com/privacy?hl=pl (this data includes information about activities on the Online Store’s website – including information about the device, visited websites, purchases, displayed ads, and how services are used).

4.4.7.3.Pinterest Europe Limited – The Administrator may use social plugins from Pinterest (e.g., sharing content from the Online Store on one’s Pinterest profile) on the Online Store’s website and, in connection with this, collects and shares personal data of the Service User using the Online Store’s website with Pinterest Europe Limited (2nd Floor Palmerston House, Fenian Street, Dublin 2 Dublin, Ireland) to the extent and in accordance with the privacy principles available here: https://policy.pinterest.com/en/privacy-policy).

5. PROFILING IN THE ONLINE STORE

5.1. The GDPR Regulation imposes on the Administrator the obligation to inform about automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR Regulation, and – at least in these cases – to provide meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject. With this in mind, the Administrator provides information regarding possible profiling in this point of the privacy policy.

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 of using Electronic Services in the Online Store. The effect of using profiling in the Online Store may be, for example, granting a discount to a given person, sending them a discount code, reminding them about unfinished purchases, sending a Product proposal that may match their interests or preferences, or offering better conditions compared to the standard offer of the Online Store. Despite profiling, the individual freely decides whether they want to use the discount or better conditions received in this way and make a purchase in the Online Store.

5.3. Profiling in the Online Store involves the automatic analysis or prediction of a given person’s behavior on the Online Store’s 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 history of past purchases in the Online Store. A condition for such profiling is that the Administrator has the personal data of the given person in order to then send them, 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 him or her or similarly significantly affects him or her.

6. RIGHTS OF THE DATA SUBJECT

6.1. Right of access, rectification, restriction, erasure, or portability – the data subject has the right to request from the Administrator access to their personal data, their rectification, erasure (“right to be forgotten”) or restriction of processing, and has the right to object to processing, as well as the right to data portability. Detailed conditions for exercising the aforementioned rights are indicated in Articles 15-21 of the GDPR Regulation.

6.2. Right to withdraw consent at any time – a person whose data is processed by the Administrator on the basis of expressed consent (pursuant to Article 6(1)(a) or Article 9(2)(a) of the GDPR Regulation) has the right to withdraw consent at any time without affecting the lawfulness of processing carried out on the basis of consent before its withdrawal.

6.3. Right to lodge a complaint with a supervisory authority – a person whose data is processed by the Administrator has the right to lodge a complaint with a supervisory authority in the manner and procedure specified in the provisions of 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 – on grounds relating to their particular situation – to processing of personal data concerning them which is based on Article 6(1)(e) (public interest or official authority) or (f) (legitimate interest of the administrator), including profiling based on these provisions. In such a case, the Administrator shall no longer process the personal data unless the Administrator demonstrates compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject or for the establishment, exercise, or defense of legal claims.

6.5. Right to object to direct marketing – if personal data are processed for direct marketing purposes, the data subject has the right to object at any time to processing of personal data concerning them for such marketing, which includes profiling to the extent that it is related to such direct marketing.

6.6. To exercise the rights referred to in this point of the privacy policy, you can contact the Administrator by sending a written message or 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’s website.

7. COOKIES IN THE ONLINE STORE AND ANALYTICS

7.1. Cookies are small text files, sent by the server and stored on the side of the person visiting the Online Store’s website (e.g., on the hard drive of a computer, laptop, or on the memory card of a smartphone – depending on the device used by the visitor to our Online Store). Detailed information on Cookies, as well as their history, can be found, among others, here: https://pl.wikipedia.org/wiki/HTTP_cookie.

7.2. The Administrator may provide a tool on the Online Store’s website for easy and active management of Cookies – available upon first entry to the site, and then, after closing it, available in the bottom corner of the page. Active management allows, among other things, to check which Cookies are or may be stored when using the site, as well as to select and subsequently change the scope and purposes of using Cookies in relation to the device and the person visiting the site. When starting to use the site, the visitor will be asked to choose Cookie settings. These can be changed later by modifying the settings within this tool available on the site.

7.3. Below, the Administrator provides a number of information regarding the use of Cookies on the Online Store’s website, their types and purposes of use, and their management using, for example, web browser settings and/or the Cookie management tool available on the site. The Administrator encourages the use of the Cookie management tool available on the site, which allows for easy active management of Cookies while using the site, and if it is not available, to familiarize yourself with the information below regarding, among other things, managing Cookies from the browser level.

7.4. Cookies that may be sent by the Online Store’s website can be divided into different types, according to the following criteria:

By their provider:

By their storage period on the device of the person visiting the Online Store’s website:

By their purpose of use:

1) first-party (created by the Administrator’s Online Store) and

2) third-party (other than the Administrator)

1) session (stored until logging out of the Online Store or closing the web browser) and

2) persistent (stored for a specified period, defined by the parameters of each file or until manually deleted)

1) essential (enabling the proper functioning of the Online Store’s website),

2) functional/preference (enabling the adaptation of the Online Store’s website to the preferences of the person visiting the site),

3) analytical and performance (collecting information about how the Online Store’s website is used),

4) marketing, advertising, and social (collecting information about the person visiting the Online Store’s website to display ads to that person, personalize them, measure their effectiveness, and conduct other marketing activities, including on websites separate from the Online Store’s website, such as social media platforms or other sites belonging to the same advertising networks as the Online Store)

7.5. The Administrator may process data contained in Cookies when visitors use the Online Store’s website for the following specific purposes:

Purposes of using Cookies in the Administrator’s Online Store	identifying Service Users 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)
	adapting the content of the Online Store’s website to the individual preferences of the Service User (e.g., regarding colors, font size, page layout) and optimizing the use of the Online Store’s pages (functional/preference Cookies)
	conducting anonymous statistics showing how the Online Store’s website is used (analytical and performance Cookies)
	displaying and rendering advertisements, limiting the number of ad impressions and ignoring ads that the Service User does not want to see, measuring ad effectiveness, and personalizing ads, i.e., examining the behavioral characteristics of Online Store visitors through anonymous analysis of their actions (e.g., repeated visits to specific pages, keywords, etc.) to create their profile and deliver ads tailored to their predicted interests, also when they visit other websites in the advertising network of Google Ireland Ltd. or Meta Platforms Ireland Ltd. (marketing, advertising, and social Cookies)

7.6. It is possible to check which Cookies are currently being sent by the Online Store’s website, regardless of the web browser, using tools available, for example, at: https://www.cookiemetrix.com or https://www.cookie-checker.com.

7.7. By default, most web browsers available on the market accept the saving of Cookies. Everyone has the option to define the conditions for using Cookies through their own web browser settings. This means that you can, for example, partially restrict (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 be impossible to complete the Order path through the Order Form due to Products not being remembered in the cart during subsequent steps of placing an Order).

7.8. Browser settings regarding Cookies are important from the perspective of consent to the use of Cookies by our Online Store – according to regulations, such consent can also be expressed 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 on the following pages (just click on the link):

in Microsoft Edge browser

7.9. 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 to conduct statistics and analyze traffic in the Online Store. The collected data is processed within these services to generate statistics helpful in administering the Online Store and analyzing traffic in the Online Store. This data is aggregated. When using the above services in the Online Store, the Administrator collects data such as the sources and medium of acquiring Online Store visitors and their behavior on the Online Store’s website, information about the devices and browsers they use to visit the site, IP and domain, geographical data, and demographic data (age, gender) and interests.

7.10. It is possible for an individual to easily block the sharing of information about their activity on the Online Store’s website with Google Analytics – for this purpose, one can, for example, install a browser add-on provided by Google Ireland Ltd. available here: https://tools.google.com/dlpage/gaoptout?hl=pl.

7.11. In connection with the Administrator’s ability to use analytical and advertising services provided by Google Ireland Ltd. in the Online Store, the Administrator indicates that full information on the principles of processing data of persons visiting the Online Store (including data stored in Cookies) by Google Ireland Ltd. can be found in the privacy policy of Google services available at the internet address: https://policies.google.com/technologies/partner-sites.

8. FINAL PROVISIONS

8.1. The Online Store may contain links to other websites. The Administrator encourages you to familiarize yourself with the privacy policy established there after navigating to other sites. This privacy policy applies only to the Administrator’s Online Store.