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PRIVACY POLICY

LOCAL HEROES STORE PRIVACY POLICY

 

This Privacy Policy (hereinafter: "Policy") contains information about the processing of your personal data in connection with the use of the online store "LOCAL HEROES", operating at the Internet address www.localheroesstore.com (hereinafter: "Store").

 

Any capitalized terms not otherwise defined in the Policy shall have the meaning given to them in the Terms and Conditions, available at: https://localheroesstore.com/us/terms-and-conditions.

 

Personal data controller

 

The administrator of your personal data is FCGROUP limited liability company with its registered office in Warsaw (registered office address:  Wróbla 35 street, 02-736 Warsaw), entered in the Register of Entrepreneurs of the National Court Register kept by the District Court for the city of Warsaw under KRS no. Warsaw, XII Commercial Department of the National Court Register under KRS number: 0000688194, holding NIP: 7010706892, REGON number: 367899648, holding share capital of PLN 7,778,000.00 (hereinafter: "Administrator").

 

Contacting the Administrator

 

In all matters related to the processing of personal data, you can contact the Administrator via e-mail, at: [email protected].

 

Data Protection Officer

 

You may contact the Data Protection Officer appointed by the Administrator ( Mr. Marek Wolski, [email protected])  by email, at [email protected].

 

Data protection measures

 

The Administrator applies modern organizational and technical safeguards to ensure the best possible protection of your personal data and ensures that it is processed in accordance with the provisions 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 the repeal of Directive 95/46/EC (General Data Protection Regulation) (hereinafter: "RODO"), the Act of May 10, 2018 on the protection of personal data and other data protection regulations.

 

Information about the personal data processed

 

The use of the Store requires the processing of your personal data. Below you will find detailed information about the purposes and legal grounds for processing, as well as the period of processing and the obligation or voluntariness of providing it.

 

 

Purpose of processing

Personal data processed

Legal basis

 

Conclusion and execution of the Agreement for the provision of the Account Service

  1. name
  2. email address

Article 6(1)(b) of the RODO

 

(processing is necessary for the performance of the Agreement for the provision of the Account Service concluded with the data subject or for taking steps to conclude the Agreement)

 

Provision of the personal data is a condition for the conclusion and performance of the contract for the provision of the Account Service (their provision is voluntary, but the consequence of their failure will be the inability to conclude and perform the contract, including the creation of an Account).

 

The Administrator will process the personal data until the statute of limitations for claims under the Agreement for the provision of Account Services.

 

 

 

 

Purpose of processing

Personal data processed

Legal basis

 

Conclusion and execution of the Sales Agreement

  1. name
  2. email address
  3. phone number
  4. address
  5. delivery address (street, house number, apartment number, town, postal code, country)
  6. optional - company and TIN

Article 6(1)(b) of the RODO

 

(Processing is necessary for the performance of the Sales Agreement concluded with the data subject or to take steps to conclude it)

 

Provision of the above personal data is a condition for the conclusion and performance of the Sales Agreement (their provision is voluntary, but the consequence of their failure will be the inability to conclude and perform the Sales Agreement).

 

The Administrator will process the above personal data until the statute of limitations for claims under the Sales Agreement.

 

 

 

 

Purpose of processing

Personal data processed

Legal basis

 

Conclusion and execution of the Newsletter Delivery Agreement

email address

Article 6(1)(b) of the RODO

 

(Processing is necessary for the performance of the Newsletter Delivery Agreement entered into with the data subject, or for taking action to enter into the Agreement)

 

and

 

Article 6(1)(f) RODO

 

(Processing is necessary for the purpose of realization of the Administrator's legitimate interests, in this case to inform about news and promotions available in the Store)

 

Provision of the personal data is voluntary, but necessary in order to receive the Newsletter (the consequence of failure to do so will be the inability to receive the Newsletter).

 

The Administrator will process the above personal data until an objection is successfully raised or the purpose of the processing is achieved, or until the statute of limitations for claims under the Newsletter Delivery Agreement expires (whichever comes first).

 

 

 

 

 

Purpose of processing

Personal data processed

Legal basis

 

Maintaining the Administrator's profiles on social networking sites (hereinafter: "Sites")

  1. your profile names
  2. the data you put on your profile as "public"

Article 6(1)(f) RODO

 

(Processing is necessary for the purpose of the Administrator's legitimate interests, in this case to maintain profiles on the Services)

 

Provision of the personal data is voluntary, but necessary for you to use the Administrator's profile on a given Service (the consequence of failure to do so will be the inability to use the Administrator's profile).

 

The Administrator will process the personal data until an objection is successfully raised or the purpose of the processing is achieved (whichever comes first).

 

The Administrator informs you that the personal data processed for the purpose described above is processed only to the extent of your use of the Administrator's profile, and to the extent of your other use of the Services, the terms and conditions established by the administrators of those Services shall apply.

 

You should direct any questions or claims arising from your remaining use of the Services directly to their administrators.

 

 

 

 

Purpose of processing

Personal data processed

Legal basis

 

Conducting the complaint procedure

  1. name
  2. email address

Article 6(1)(c) of the RODO

 

(Processing is necessary to fulfill a legal obligation incumbent on the Administrator, in this case obligations:

  • To respond to the complaint - Article 7a of the Law on Consumer Rights.
  • Exercise of the Customer's rights under the provisions on the Administrator's liability in the event of non-compliance of the Goods with the Contract of Sale or the Object of Digital Performance with the Contract relating to it)

 

Provision of the aforementioned personal data is a condition for receiving a response to a complaint or realization of the Customer's rights under the provisions on the Administrator's liability in the event of non-compliance of the Goods with the Sales Agreement or the Subject of the digital performance with the Agreement relating to it (their provision is voluntary, but the consequence of their failure will be the inability to receive a response to a complaint and the realization of the aforementioned rights).

 

The Administrator will process the personal data for the time of the complaint procedure, and in the case of realization of the aforementioned rights of the Client - until they expire.

 

 

 

 

Purpose of processing

Personal data processed

Legal basis

 

Sending e-mail notifications

email address

Article 6(1)(f) RODO

 

(Processing is necessary for the purpose of realization of the legitimate interests of the Administrator, in this case to inform Customers about the activities undertaken in connection with the execution of Agreements concluded with Customers)

 

Provision of the personal data is voluntary, but necessary in order to receive information on activities related to the execution of the Agreements concluded with the Customers (the consequence of their failure to do so will be the inability to receive the aforementioned information).

 

The Administrator will process the personal data until an objection is successfully raised or the purpose of the processing is achieved (whichever comes first).

 

 

 

 

 

 

Purpose of processing

Personal data processed

Legal basis

 

Organization of promotional actions (including contests and loyalty programs)

  1. name
  2. email address
  3. other data necessary for the organization of promotional activities

Article 6(1)(f) RODO

 

(Processing is necessary for the purpose of realization of the Administrator's legitimate interests, in this case the proper conduct of promotional campaigns)

 

 

Provision of the personal data is voluntary, but necessary to participate in the promotional action (the consequence of their failure will be the inability to participate in the action).

 

The Administrator will process the personal data until an objection is successfully raised or the purpose of the processing is achieved (whichever comes first).

 

 

 

Purpose of processing

Personal data processed

Legal basis

 

Fulfillment of tax obligations (including issuance of VAT invoice, keeping accounting records)

  1. name/company
  2. residence/site address
  3. NIP

Article 6(1)(c) of the RODO

 

(Processing is necessary to fulfill a legal obligation of the Administrator, in this case obligations under tax law)

 

Provision of the personal data is voluntary, but necessary in order for the Administrator to fulfill its tax obligations (the consequence of failure to do so will be the Administrator's inability to fulfill the aforementioned obligations).

 

The administrator will process the above personal data for a period of 5 years from the end of the year in which the deadline for payment of tax for the previous year expired.

 

 

 

 

 

 

Purpose of processing

Personal data processed

Legal basis

 

Fulfillment of obligations related to the protection of personal data

  1. name
  2. contact information you provided (e-mail address; mailing address; telephone number)

Article 6(1)(c) of the RODO

 

(Processing is necessary for the fulfillment of a legal obligation incumbent on the Administrator, in this case obligations under data protection laws)

 

Provision of the personal data is voluntary, but necessary in order for the Administrator to properly perform its duties under data protection regulations, including the exercise of rights granted to you by the RODO (the consequence of failure to provide the aforementioned data will be the inability to properly exercise the aforementioned rights).

 

The controller will process the above personal data until the expiration of the statute of limitations for claims for violation of data protection laws.

 

 

 

 

 

 

Purpose of processing

Personal data processed

Legal basis

 

Determination, investigation or defense of claims

  1. name/company
  2. email address
  3. residence/site address
  4. PESEL number
  5. NIP

Article 6(1)(f) RODO

 

(Processing is necessary for the purpose of realizing the legitimate interests of the Administrator, including in the case of establishing, investigating or defending against claims that may arise in connection with the performance of the Agreements concluded with the Administrator)

 

Provision of the above personal data is voluntary, but necessary in order to establish, assert or defend against claims that may arise in connection with the performance of the Agreements concluded with the Administrator (the consequence of not providing the above data will be the Administrator's inability to take the above actions)

 

The Administrator will process the above personal data until the expiration of the statute of limitations for claims that may arise in connection with the performance of the Agreements concluded with the Administrator.

 

 

 

 

 

 

Purpose of processing

Personal data processed

Legal basis

 

Analysis of your activity in the Store

  1. date and time of visit
  2. IP number of the device
  3. type of operating system of the device
  4. approximate location
  5. type of web browser
  6. time spent in the Store
  7. viewed Goods
  8. visited subpages and other actions taken within Store

Article 6(1)(f) RODO

 

(Processing is necessary for the Administrator's legitimate interests, in this case to obtain information about your activity in the Store)

 

Provision of the personal data is voluntary, but necessary for the Administrator to obtain information about your activity in the Store (the consequence of not providing it will be the Administrator's inability to obtain the aforementioned information).

 

The administrator will process the above personal data until an objection is successfully raised or the purpose of the processing is achieved.

 

 

 

 

 

 

Purpose of processing

Personal data processed

Legal basis

 

Administering the Store

  1. IP address
  2. server date and time
  3. web browser information
  4. operating system information

 

The above data is recorded automatically in the so-called server logs, each time you use the Store (administering it without the use of server logs and automatic recording would not be possible).

Article 6(1)(f) RODO

 

(Processing is necessary for the Administrator's legitimate interests, in this case to ensure the proper operation of the Store)

 

Provision of the personal data is voluntary, but necessary to ensure the proper operation of the Store (the consequence of their absence will be the inability to ensure the proper operation of the Store).

 

The administrator will process the above personal data until an objection is successfully raised or the purpose of the processing is achieved.

 

                   

 

Profiling

 

In order to create your profile for marketing purposes and to target you with direct marketing tailored to your preferences, the Administrator will process your personal data by automated means, including profiling - but this will not have any legal effect on you or similarly materially affect you.

 

The scope of the personal data profiled corresponds to the scope indicated above with respect to the analysis of your activity in the Store and the data you save in your Account.

 

The legal basis for the processing of personal data for the above purpose is Article 6(1)(f) of the RODO, according to which the Administrator may process personal data in order to realize its legitimate interest, in this case to conduct marketing activities tailored to the preferences of recipients. Provision of the personal data is voluntary, but necessary for the realization of the aforementioned purpose (the consequence of failing to provide such data will be the Administrator's inability to conduct marketing activities tailored to the recipients' preferences).

 

The controller will process personal data for profiling purposes until you successfully object or the purpose of the processing is achieved.

 

Recipients of personal data

 

Recipients of personal data may be the following external entities cooperating with the Administrator:

 

  1. Entities belonging to the Wirtualna Polska capital group;
  2. Hosting providers;
  3. Software providers;
  4. Consulting, auditing and law firms;
  5. Postal and courier companies;
  6. Banks;
  7. Online payment system providers;
  8. Newsletter provider;
  9. Entities implementing the sending of e-mails related to the delivery of Goods;
  10. Companies that provide tools to analyze activity in the Store and target direct marketing to individuals using it (including Google Analytics);
  11. Accounting services company.

 

In addition, personal data may also be transferred to public or private entities if such an obligation arises from generally applicable laws, a final court judgment or a final administrative decision.

 

Transfer of personal data to a third country

 

In connection with the Administrator's use of services provided by Google LLC , your personal data may be transferred to the following third countries: United Kingdom, Canada, USA, Chile, Brazil, Israel, Saudi Arabia, Qatar, India, China, South Korea, Japan, Singapore, Taiwan (Republic of China), Indonesia and Australia. The basis for the transfer of data to the third countries is:

 

  • in the case of the United Kingdom, Canada, Israel and Japan, decisions of the European Commission stating an adequate level of personal data protection in each of the third countries;
  • in the case of the USA, Chile, Brazil, Saudi Arabia, Qatar, India, China, South Korea, Singapore, Taiwan (Republic of China), Indonesia, and Australia - contractual clauses providing an adequate level of protection, in accordance with the standard contractual clauses set forth in Commission Implementing Decision (EU) 2021/914 of June 4, 2021 on standard contractual clauses for the transfer of personal data to third countries under Regulation (EU) 2016/679 of the European Parliament and of the Council.

 

You can obtain from the Administrator a copy of the data transferred to a third country.

 

Entitlements

 

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

 

  1. The right to know what personal data concerning you is processed by the Administrator and to receive a copy of this data (the so-called right of access). The issuance of the first copy of data is free of charge, for subsequent copies the Administrator may charge a fee;
  2. if the processed data becomes outdated or incomplete (or otherwise incorrect), you have the right to request rectification;
  3. In certain situations, you may ask the Administrator to delete your personal data, such as when:
    1. the data will cease to be needed by the Administrator for the purposes it informed;
    2. you have effectively withdrawn your consent to data processing - unless the Administrator has the right to process the data on another legal basis;
    3. processing is unlawful;
    4. the need to delete the data arises from the Administrator's legal obligation;
  4. if your personal data is processed by the Administrator on the basis of your consent to processing or for the purpose of performing the Agreement concluded with it, you have the right to transfer your data to another administrator;
  5. where personal data is processed by the Administrator based on your consent to processing, you have the right to withdraw this consent at any time (withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal);
  6. if you consider that the processed personal data is incorrect, its processing is unlawful, or the Administrator no longer needs certain data, you can request that for a certain necessary period (e.g., to verify the correctness of the data or to assert claims) the Administrator not perform any operations on the data, but only store it;
  7. You have the right to object to the processing of personal data based on the legitimate interests of the Administrator. If you successfully object, the Administrator will stop processing your personal data for the above-mentioned purpose;
  8. you have the right to lodge a complaint with the President of the Office for Personal Data Protection if you consider that the processing of your personal data violates the provisions of the RODO.

 

Cookies

  1. The Administrator informs that the Store uses "cookies" (cookies), installed on your terminal device. These are small text files that can be read by the Administrator's system, as well as by systems belonging to other entities whose services are used by the Administrator (e.g. Facebook, Google).
  2. The administrator uses cookies for the following purposes:
    1. ensuring proper operation of the Store - thanks to cookies, it is possible for the Store to operate smoothly, use its functions and move conveniently between individual subpages;
    2. increase the comfort of browsing the Store - thanks to cookies, it is possible to detect errors on some subpages and to continuously improve them;
    3. creation of statistics - cookies are used to analyze how users use the Store. Thanks to this it is possible to constantly improve the Store and adjust its operation to the users' preferences;
    4. conduct marketing activities - thanks to cookies, the Administrator can target users with ads tailored to their preferences.
  3. The administrator may place both permanent and temporary (session) files on your device. Session files are usually deleted when you close your browser, while closing your browser does not delete permanent files.
  4. Information about the cookies used by the Administrator is displayed in the panel located in the central part of the Store's website. Depending on your decision, you can enable or disable cookies of particular categories (except for essential cookies) and change these settings at any time using the "Cookie Preference" tab located in the footer of the Store's website.
  5. The data collected through cookies does not allow the Administrator to identify you.
  6. Through most commonly used browsers, you can check whether cookies have been installed on your end device, as well as delete installed cookies and block the Store from installing them in the future. However, disabling or restricting cookies may cause quite serious difficulties in using the Store, e.g., in the form of the need to log in to each subpage, longer loading time of the Store's website, limitations in the use of certain functionalities.

 

Final provisions

 

To the extent not regulated by the Policy, the generally applicable data protection regulations shall apply.

 

The policy is effective as of 01.01.2023