PRIVACY POLICY AND COOKIES POLICY

AB TRADE Sp. z o.o.

PRIVACY POLICY

I. Definitions

2. The terms used in this document shall mean:

2.1   Privacy Policy - this Privacy Policy.

2.2   Personal data - means all information relating to an identified or identifiable natural person ("data subject"), an identifiable natural person is a person whose identity can be established directly or indirectly, in particular with regard to identification, such as name, identification number, location data, online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.

2.3   The data subject –any natural person whose personal data is processed by the Administrator.

2.4   Data protection regulations – means any applicable in the case of generally applicable provisions of the European Union, as well as locally relevant provisions of the Member States, including, among others, laws, directives and regulations, concerning the protection of personal data, in particular the GDPR (in the meaning given below).

2.5   GDPR – European Union General Data Protection Regulation - (EU) 2016/679 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 (General Data Protection Regulation);

2.6   Data administrator – ABTRADE Sp. z o.o. with headquarters in Krakow, at: Al. Juliusza Słowackiego 5, 31-159 Krakow.

2.7   AB TRADE – AB TRADE Sp. z o.o. with headquarters in Krakow, at: Al. Juliusza Słowackiego 5, 31-159 Kraków.

II. Processing of personal data

1. In connection with its business activities, the Data Administrator collects data for specified, legitimate purposes, processes them in accordance with the law and does not subject further processing incompatible with these purposes. Data is collected only in an adequate, necessary and range in relation to the purposes for which they are processed.
2. The administrator makes every effort to protect data against unauthorized access by third parties and in this respect applies organizational and technical security measures at a high level. The Administrator does not make the data available to any unauthorized persons, in accordance with the applicable legal provisions in this regard, to the recipients.
3. Administrators / Entities entrusted with the processing of your personal data

¾    Data administrator

¾    Trusted partners

• Google Inc.

https://www.google.com/about/

• Facebook

https://www.facebook.com/

III. Security of personal data

1. In order to ensure the integrity and confidentiality of data, the Data Administrator has implemented procedures allowing access to personal data only to authorized persons and only to the extent that it is necessary due to the tasks performed by them.
2. In addition, the data administrator undertakes all necessary actions to ensure that its subcontractors and other cooperating entities guarantee appropriate security measures whenever they process personal data at the request of the Data Administrator.
3. The Data Administrator conducts the risk analysis on an on-going basis and monitors the adequacy of data security measures applied to the identified threats. If necessary, the Data Administrator implements additional measures to increase data security.

IV. What are the purposes of processing your personal data?

1. Goals related to the sale of products by the adam-baron.pl online store and the provision of related services

Your personal data is processed in order to conclude and implement contracts for buying / selling ADAM BARON products in the adam-baron.pl online store, shipping products, handling product returns, handling complaints and guarantees, and handling other matters related to purchase / sale contracts in the adam-baron.pl online store.

2. Marketing and analytical objectives

With your consent, personal data may be processed for marketing purposes, including to send you commercial or marketing information about ADAM BARON products (newsletter), profiling and for analytical purposes, as well as detection of bots and fraud and statistical measurements. In addition, your data can also be processed to match the content displayed on websites, including commercial or marketing messages, to your interests.

If consent is given, the data may be processed by the Data Administrator and Trusted Partners.

3. Internet social media

If you are a member of the community operating around ADAM BARON's social profiles, conducted as part of popular online social networks, your data is processed in order to enable management and ongoing management of these profiles, including, inter alia, to communicate with members of these communities, organize promotional campaigns or events - on the principles defined by the functionalities and regulations of individual social media platforms. In addition, they can be processed for claims and defense against claims and for statistical and analytical purposes.

4. Traditional or e-mail correspondence

If you send to AB TRADE by traditional mail or e-mail, correspondence not related to the sale of ADAM BARON products or services provided to you or other contract concluded, personal data contained in this correspondence are processed only for the purpose of communication and settlement of the case, this correspondence applies. Only personal data relevant to the case to which the correspondence relates are processed.

5. Contact by phone

If you contact AB TRADE by phone, in matters not related to your contract or services provided to you, we require personal data only if it is necessary to handle the matter covered by the contact.

6. Processing of personal data in IT applications

If your personal data is processed in the ICT environment, it means that they can also be temporarily stored and processed to ensure the security and correct functioning of IT systems - e.g. in connection with modifications, changes and functional development of the application, detection of errors and irregularities in applications, making backup copies of applications, as well as security and protection against abuse or attacks.

7. Collection and processing of data in business relations

In connection with the conducted activity, the Administrator collects personal data also in other cases - e.g. during business meetings, at industry meetings or by exchanging business cards - for purposes related to establishing and maintaining business contacts.

In connection with the cooperation of the Data Administrator with business partners, including business clients and suppliers, the Data Administrator processes the contact details of people indicated as business contacts in relation to the Data Administrator, e.g. those responsible for the partner's performance of the contract with the Data Administrator. The data administrator processes the contact details of such persons in order to communicate with business partners on an ongoing basis and to maintain contact with them.

V. What are the legal grounds for processing your personal data?

1. Objectives related to the sale of products through the online store adam-baron.pl and provide related services

The legal basis for the processing of your personal data is the performance of the contract to which the data subject is a party (Article 6 paragraph 1 letter b of the GDPR).

2. Marketing and analytical objectives

The legal basis for the processing of your data for marketing purposes is your voluntary consent to data processing (Article 6 paragraph 1 letter a of the GDPR).

In order to match the content displayed on websites, including commercial or marketing communications, your interests, profiling and analytical purposes, as well as detection of bots and fraud and statistical measurements (Google Analytics), the legal basis for the processing of your personal data is the legitimate interest of the Administrator data (Article 6 paragraph 1 letter f of the GDPR).

3. Internet social media

The legal basis for the processing of your personal data is the performance of the contract to which the data subject is a party (Article 6 paragraph 1 letter f of the GDPR).

4. Traditional or e-mail correspondence

The legal basis for the processing of your personal data is the legitimate interest of the Data Administrator (Article 6 paragraph 1 letter f of the GDPR), consisting in the correspondence addressed to him in connection with his business activity.

5. Contact by phone

The legal basis for the processing of your personal data is the legitimate interest of the Data Administrator (Article 6 paragraph 1 letter f of the GDPR), consisting in the necessity to settle a reported matter related to the business activity.

6. Processing of personal data in IT applications

The legal basis for the processing of your personal data is the legitimate interest of the Data Administrator (Article 6 paragraph 1 letter f of the GDPR).

8. Collection and processing of data in business relations

The legal basis for the processing of your personal data is the legitimate interest of the Data Administrator (Article 6 paragraph 1 letter f of the GDPR) of the RODO, consisting in establishing a network of contacts in connection with business activity or involving communication with business partners.

7. Data processing in connection with the provision of services or the performance of other contracts

The rules of processing your personal in connection with the offered services related to the sale of products by AB TRADE, are determined by separate policies, available on the websites of these services - e.g. PayU, courier companies,

VI. The requirement to provide personal data

1. Providing personal data in order to conclude and implement contracts for the purchase / sale of ADAM BARON products in the adam-baron.pl online store, product dispatch, product returns, complaint handling and warranty, and other issues related to purchase / sale contracts in the online store adam-baron.pl, is necessary for the above-mentioned conclusion and performance of contracts and provision of services. In the absence of personal data, contracts can’t be included and services can’t be provided.
2. Providing personal data for marketing purposes, including profiling and for analytical purposes is voluntary. If you do not agree to the processing of personal data left by you in the use of the online store adam-baron.pl, including those stored in cookies - your personal data will not be processed for this purpose.
3. Data processing to match the content displayed on websites, including commercial or marketing messages, your interests, discovery and abuse in AB TRADE services, statistical measurement is necessary to ensure high quality of AB TRADE services. Not collecting your personal data for these purposes may prevent the correct provision of services.

VII. For what period will your personal data be processed?

1. The processing time of your data depends on the purpose of data processing and the type and scope of services provided. The specified data processing period may be the result of regulations, if they form the basis for processing. In the case of data processing based on the legitimate interest of the Data Administrator - for example for statistical, billing, claims or security reasons - the data is processed for a period enabling its implementation or for reporting effective opposition to data processing. If the processing is based on your consent, the data is processed until it is withdrawn.
2. If the basis for the processing of your data is indispensable for the conclusion and performance of the contract, including the purchase / sale of ADAM BARON products in the adam-baron.pl online store, your personal data will be processed until it is resolved.
3. Your personal data will be processed for marketing purposes until you withdraw your consent to such processing.
4. In terms of matching content displayed on adam-baron.pl websites, including commercial or marketing communications, to your interests, as well as detection of bots and frauds, analytical purposes and statistical measurements, your data will be processed for these purposes until the opposition or until you finish using AB TRADE's offer and services.
5. The processing of personal data may be extended if the processing is necessary to establish, investigate or defend against any claims, and after that period, only in the case and to the extent that it will be required by law. After the processing period, the data is irreversibly deleted or anonymized.
6. Trusted Partners process data for a period of time necessary to achieve the purpose of processing, as defined in the Trusted Partner's appropriate privacy policy.

VIII. To which recipients your personal data will be transmitted?

1. In connection with the conduct of business requiring the processing of personal data, your data may be transferred to external entities that process personal data at the request of the Data Administrator, including: providers of IT services and solutions, entities providing legal, accounting or auditing services, entities providing consulting services, entities that mediate in electronic payments, entities providing postal or courier services, marketing agencies, recruitment agencies, research companies, where such entities process data only in accordance with with Data Administrator commands.
2. Your data may also be transferred to entities authorized to obtain it on the basis of applicable law.

IX. Transmission of data outside the European Economic Area

1. The data controller transfers personal data outside the European Economic Area (EEA) only when it is necessary and with an adequate level of protection, primarily through:

¾    cooperation with entities, processing personal data in countries for which an appropriate decision of the European Commission has been issued;

¾    use of standard contractual clauses issued by the European Commission;

¾    applying binding corporate rules, approved by the competent supervisory authority;

¾    in the case of data transfer to the USA - cooperation with entities participating in the Privacy Shield program, approved by the decision of the European Commission.

X. What are your rights related to the processing of personal data?

3. In connection with the processing of your personal data, you have the following rights:

3.1   the right to access your personal data, including obtaining a copy of the data

You can get information on how and to what extent we process your data and additionally a copy of your personal data. In case your request includes copies of data, you can help us by indicating a copy of which data you would like to receive. The data administrator may charge a fee for the second and subsequent copies, about which you will be notified. The amount of the fee will correspond to the costs of its preparation;

3.2   the right to request the correction of personal data

You can request the rectification of your personal data (if they have been incorrectly saved or if they have changed);

3.3   the right to delete personal data (in certain situations)

You can request removal of your personal data (if there is no basis for the data controller to process it);

3.4   the right to limit data processing

You can request a restriction on the processing of your personal data (if you want the Data Administrator to process your personal data only to a limited extent, until your opposition or request for correction of personal data is considered, and if you want the data to be stored in relation to your claims);

3.5   the right to limit data processing

You can request a restriction on the processing of your personal data (if you want the Data Administrator to process your personal data only to a limited extent, until your opposition or request for correction of personal data is considered, and if you want the data to be stored in relation to your claims);

3.6   the right to object to the processing of your data

If the processing of your data is based on the legitimate interest of the Data Administrator, you can oppose such processing;

3.7   the right to lodge a complaint with the supervisory body dealing with the protection of personal data

You have the right to lodge a complaint with the supervisory body, ie the President of the Office for Personal Data Protection. More information on the office's website;

To the extent that your data is processed on the basis of consent or as part of the services provided (data is necessary for the conclusion and performance of contracts and provision of services), you may additionally use the following rights:

3.8   the right to withdraw consent in the scope in which they are processed on this basis.

Withdrawal of consent does not affect the lawfulness of the processing that was made on the basis of consent before its withdrawal;

3.9   the right to transfer personal data, i.e. to receive from the Administrator your personal data, in a structured, commonly used machine-readable format

you can request the transfer of your data in a structured, commonly used, machine-readable format;

In order to benefit from these rights the controller provides the following communication channels:

¾    written form - address: AB TRADE Sp. z o.o., Al. Juliusza Słowackiego 5, 31-159 Kraków.

¾    e-mail - address: kontakt@abtrade.pl

Proposal for implementation of the rights of data subjects, should as far as possible indicate precisely what the request. In particular:

¾    what permission the person submitting the application wants to use (e.g. the right to receive a copy of the data, the right to delete data, etc.);

¾    what data processing process the request is for (e.g. activity on the www.adam-baron.pl website, receiving a newsletter with marketing information, etc.);

¾    what purposes the data being requested (eg. marketing goals, objectives analysis, etc.);

If the Data Administrator is unable to determine the content of the request or identify the person submitting the application based on the submitted application, he will ask the applicant for additional information.

A response to the notification will be given within 30 days of its receipt. If it is necessary to extend this deadline, the Data Administrator will inform the applicant about the reasons for such extension.

In the case of an application submitted by e-mail, the answer will be given to the e-mail address from which the application was sent. In the case of an application submitted in writing (letter), the answer will be given in writing (ordinary letter) to the address indicated by the applicant, unless the letter will be sent to the e-mail address and if the e-mail address will be given in the application.

XI. Contact with the Data Administrator

In matters concerning the protection of personal data and the use of rights related to the processing of these data, you can contact through the following communication channels:

• written form - address: AB TRADE Sp. z o.o., Al. Słowackiego 5, 31-159 Kraków
• e-mail - address: kontakt@abtrade.pl

COOKIES POLICY

XII. Cookies and other technologies

1. AB TRADE informs that it uses cookie technology (text files) and other technologies on the websites of the online store adam-baron.pl to record information about websites or subpages visited by the user and activity.
2. Cookies (so-called "cookies") are tiny portions of information saved by a web browser. The cookie has no effect on the software or hardware. Cookies are associated only with the browser of a specific terminal device, without providing the user's first and last name (anonymous user). This is information saved by the server on the end device of the website user, which the server can read each time it connects to the user's device.
3. The term "other technologies" refers to min. Web beacons, pixels and anonymous ad network tags.
4. Because network ads and signals must be transmitted to the web browser directly from the ad network servers, these networks can display, edit or enter their own cookies as if the user requested a website from their website.
5. For purposes necessary to conclude or perform a contract with the user and to provide a more tailor-made offer, and in the event of explicit consent of the data subject, AB TRADE may use profiling, which means a form of processing that involves the use of personal data for analysis or predictions about your personal preferences and interests.

XIII. Types of cookies

1. As part of AB TRADE websites, the following types of cookies are used:

1.1.Authentication

„necessary cookies”- information enabling the use of services available as part of the website, e.g." authentication cookies "used for services that require authentication as part of the website;

1.2. Security

"Cookie files used to ensure security" - information used to ensure security to support mechanisms to prevent abuse of websites, including data leakage or fraud detection in the field of authentication on the website;

1.3. Preferences

"Functional cookies" - information that allows you to remember user-selected settings and personalization of the user, e.g. in terms of the selected language or region of the user, font size, website appearance, etc.;

1.4. Efficiency

"Performance" cookies - information allowing the collection of information about how to use the Internet service websites;

1.5. Advertising and Trusted Partners

"Advertising" cookies - information that enables users to provide advertising content more tailored to their interests. AB TRADE allows other entities to use cookies - so-called "Third-party cookies" - information provided to the Trusted Partners (service providers, in particular search, advertising, research on the Internet, etc.).

2. As part of the AB TRADE website, two basic types of cookies are used:

2.1. "Session" cookies - "session" cookies are temporary files that are stored on the user's end device until logging out, leaving the website or turning off the software (web browser).

2.2."Permanent" (persistent cookies) - "permanent" cookies are stored in the terminal device of the website user for the time specified in the parameters of cookies or until they are deleted by the user.

XIV. Purposes of using cookies

1. Cookies are used for purposes:

1.1.Maintaining the session of the user of the website (after logging in), thanks to which the user does not have to re-enter the login and password on each subpage of the website;

1.2.Adjusting the content of websites to user preferences and optimizing the use of websites; in particular, these files allow to recognize the user's device of the website and properly display the website, tailored to his individual needs;

1.3.Content matches for ads broadcast on the Google Display Network (remarketing);

1.4.Remembering the lack of permission to display some content in the future;

1.5.Statistical and analytical, including measuring user's behavior and traffic on the website pages using the Google Analytics mechanism;

1.6.Content matching of advertisements broadcast on AB TRADE services;

1.7.Measuring the effectiveness (conversion tracking) of campaigns on the Google Display Network, partner programs and affiliate networks;

1.8.Use of probes or surveys to examine user preferences;

XV. Social Plugins

1. Information supporting functions, providing important information and content consistent with individual user needs, coming from servers of entities running web services:

¾      Facebook, who places "Like" and "Recommend / Share" buttons on the pages of his website related to Facebook. For this purpose, the code referring to Facebook is placed on the relevant pages. Using the "Like" button or recommending an image or sections of a website, and posting a comment, the user logs in to Facebook, where the Facebook privacy rules apply, available at: http://pl-pl.facebook.com/help/cookies

¾      YouTube, who places video clips from YouTube on the pages of his site. For this purpose, the code referencing YouTube is posted on the pages. YouTube tracks the playback of video clips in accordance with the privacy practices available at: http://www.google.com/intl/en/policies/privacy/

¾      Instagram,who places buttons for adding photo and video materials on the pages of his website and the "Like" button associated with the Instagram website. For this purpose, the code referring to the Instagram website is placed on the relevant pages. Use the "Like" and comment posting a user logs on to the site Instagram, where applicable privacy policies of Instagram, available at; https://www.facebook.com/help/instagram/155833707900388

XVI. Advertising

1. Information needed to show a matched ad or to get information about visits to advertisers' sites. In a similar way, our Trusted Partners can use cookies to determine the effectiveness of advertising. Cookies and other technologies allow users to serve ads more effectively, as well as gathering audits, surveys and reports for advertisers.
2. AB TRADE informs that he is a party to the contract with:

2.1.GOOGLE Inc.

As part of advertising services, the Trusted Partners software creates on the user's device cookies, which in connection with information collected on other websites can be used to personalize content and advertisements. The privacy policies of the above-mentioned Trusted Partners are found in the addresses below:

https://policies.google.com/privacy?hl=pl

XVII. Profiling (including analyst)

1. Information on how to use websites that allow to customize ads to users' preferences and habits. On the basis of this information, we can create, for example, general user profiles (including age, gender, interests).
2. Decisions for matching the offer or provide discounts or other benefits may be taken automatically based on criteria such as gender, addresses of websites where purchases were implemented, the number and frequency of purchases carried out. Once the criteria have been met, the IT system automatically sends information about the granted benefit, e.g. discount.

XVIII. Cookies related to Internet network research / user behavior research

1. Cookies related to Internet network research / user behavior research come from the following Trusted Partners:

1.1.GOOGLE Inc.

2. AB TRADE informs that he is a party to the contract with:

2.1.GOOGLE Inc.

3. As part of analytical services, the Trusted Partners software runs an analytical code on the user's device that allows data collection and observation of user behavior and creates on the user's device cookies, which in connection with information collected on other websites can be used to personalize content, commercial messages, marketing and advertising.
4. The privacy policies of the above-mentioned Trusted Partners are found in the addresses below:

https://policies.google.com/privacy?hl=pl

XIX. How can you manage cookies

1. In many cases, software used for browsing websites (web browser) allows cookies to be stored in the user's end device by default. Website users can change cookie settings at any time. These settings can be changed particularly in such a way as to block the automatic handling of cookies in the settings of the web browser or inform about their every posting in the user's device.
2. Most browsers allow users to control cookies in their preferences. Users should read the privacy policy of these browsers to learn about their use of cookies. Restricting the possibility of setting cookie files may affect the overall quality of the use of websites.
3. If you do not want to receive cookies, you can change your web browser settings. Please be advised that limiting the use of cookies may affect some of the functionalities available on the websites of AB TRADE websites. In particular, we reserve that disabling the cookies necessary for authentication, security and preferences will hinder the use of websites, and in extreme cases may even make it impossible to use them.
4. In order to manage cookie settings, select the web browser you use from the list below and follow the instructions:

¾      Chrome™: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=pl

¾      Internet Explorer™: https://support.microsoft.com/pl-pl/help/17442/windows-internet-explorer-delete-manage-cookies

¾      Safari™: https://support.apple.com/pl-pl/guide/safari/sfri11471/mac

¾      Firefox™: https://support.mozilla.org/pl/kb/usuwanie-ciasteczek

¾      Opera™: https://www.opera.com/help/tutorials/security/privacy/

Mobile devices:

¾      Android: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=pl

¾      Safari: https://support.apple.com/pl-pl/guide/safari/sfri11471/mac

¾      Windows Phone: https://support.microsoft.com/pl-pl/help/17442/windows-internet-explorer-delete-manage-cookies

¾      Blackberry: https://help.blackberry.com/pl/blackberry-classic/10.3.1/help/mwa1334238823957.html

5. Detailed information on the possibilities and ways of handling cookies are available in the menu of the browser, most often in the section on "Help".

XX. Consent to the processing of data by cookies

1. Your data is processed by consent. Granting permission for the processing of data by cookies is voluntary, sometimes (e.g. due to logging in to remember the session) necessary. You have the right to rectify, delete or limit the processing of personal data or the right to object to the processing, as well as the right to file a complaint to the supervisory body and the right to transfer data. You have the right to request access to your personal data, change it and delete and withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of the processing which was carried out on the basis of consent before its withdrawal.

XXI. From when this Privacy Policy and Cookie Policy will apply

This Privacy Policy and Cookie Policy is valid from 15/05/2018