Privacy Policy

GENERAL PROVISIONS
GROUNDS FOR DATA PROCESSING
PURPOSE, BASIS AND PERIOD OF DATA PROCESSING IN THE ONLINE STORE
DATA RECIPIENTS IN THE ONLINE STORE
PROFILING IN THE ONLINE STORE
RIGHTS OF THE DATA SUBJECT
COOKIES IN THE ONLINE STORE AND ANALYTICS
FINAL PROVISIONS

1. GENERAL PROVISIONS

1.1. This privacy policy of the Online Store is for informational purposes, which means that it is not a source of obligations for Service Recipients or Clients of the Online Store. The privacy policy contains primarily rules regarding the processing of personal data by the Controller in the Online Store, including the grounds, purposes and scope of personal data processing and the rights of data subjects, as well as information on the use of cookies and analytical tools in the Online Store.

1.2. The controller of personal data collected via the Online Store is the company TORIN HOME SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ with its registered office in Łódź (registered office and service address: Al. T. Kościuszki 93/19, 90-436 Łódź); entered into the Register of Entrepreneurs of the National Court Register under KRS number 0001178858; registry court where the company's documentation is kept: District Court for Łódź-Śródmieście in Łódź, XX Commercial Division of the National Court Register; share capital in the amount of: 5,000.00 PLN; NIP: 7252356326; REGON: 542001630; e-mail address: office@modura.pro – hereinafter referred to as the "Controller" and being simultaneously the Service Provider of the Online Store and the Seller.

1.3. Personal data in the Online Store are processed by the Controller in accordance with applicable legal provisions, 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". Official text of the GDPR Regulation: http://eur-lex.europa.eu/legal-content/PL/TXT/?uri=CELEX%3A32016R0679.

1.4. Using the Online Store, including making purchases, is voluntary. Similarly, the associated provision of personal data by the Service Recipient or Client using the Online Store is voluntary, subject to two exceptions: (1) concluding agreements with the Controller – failure to provide, in the cases and to the extent indicated on the Online Store website and in the Terms and Conditions of the Online Store and this privacy policy, personal data necessary for the conclusion and performance of a Sales Agreement or an agreement for the provision of Electronic Services with the Controller results in the inability to conclude said agreement. Providing personal data is in such a case a contractual requirement and if the data subject wants to conclude a given agreement with the Controller, they are obliged to provide the required data. Each time, the scope of data required to conclude an agreement is previously indicated on the Online Store website and in the Terms and Conditions of the Online Store; (2) statutory obligations of the Controller – providing personal data is a statutory requirement resulting from generally applicable legal provisions imposing an obligation on the Controller to process personal data (e.g. processing data for the purpose of keeping tax or accounting books) and failure to provide them will prevent the Controller from performing these obligations.

1.5. The Controller takes special care to protect the interests of the persons whose personal data it processes, and in particular is responsible for and ensures that the data collected by it are: (1) processed lawfully; (2) collected for specified, lawful purposes and not subjected to further processing incompatible with those purposes; (3) substantively correct and adequate in relation to the purposes for which they are processed; (4) stored in a form that permits identification of data subjects for no longer than is necessary to achieve the purpose of processing and (5) processed in a manner that ensures appropriate security of personal data, including protection against unauthorized or unlawful processing and accidental loss, destruction or damage, using appropriate technical or organizational measures.

1.6. Taking into account the nature, scope, context and purposes of processing as well as the risk of violation of the rights or freedoms of natural persons with varying probability and severity of the threat, the Controller implements appropriate technical and organizational measures so that the processing takes place in accordance with this regulation and to be able to demonstrate it. These measures are reviewed and updated as necessary. The Controller applies technical measures preventing the acquisition and modification by unauthorized persons of personal data transmitted electronically.

1.7. All words, expressions 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 Terms and Conditions of the Online Store available on the Online Store website.

2. GROUNDS FOR DATA PROCESSING

2.1. The Controller is entitled 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 an agreement to which the data subject is a party, or to take steps at the request of the data subject prior to entering into an agreement; (3) processing is necessary for compliance with a legal obligation to which the Controller is subject; or (4) processing is necessary for the purposes of the legitimate interests pursued by the Controller 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 Controller requires each time the existence of at least one of the grounds indicated in point 2.1 of the privacy policy. The specific grounds for processing personal data of Service Recipients and Clients of the Online Store by the Controller are indicated in the next point of the privacy policy in relation to a given purpose of personal data processing by the Controller.

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

3.1. Each time, the purpose, basis and period as well as recipients of personal data processed by the Controller result from actions taken by a given Service Recipient or Client in the Online Store or by the Controller. For example, if the Client decides to make purchases in the Online Store and chooses personal collection of the purchased Product instead of a courier shipment, their personal data will be processed for the purpose of performing the concluded Sales Agreement, but will no longer be made available to the carrier performing shipments on behalf of the Controller.

3.2. The Controller may process personal data within the Online Store for the following purposes, on the bases, and in the periods indicated in the table below:

Purpose of data processing	Legal basis for data processing	Data storage period
Performance of a Sales Agreement or agreement for Electronic Services or taking action at the request of the data subject prior to the conclusion of the aforementioned agreements	Article 6(1)(b) of the GDPR Regulation (performance of an agreement) – processing is necessary for the performance of an agreement to which the data subject is a party, or to take steps at the request of the data subject prior to entering into an agreement	Data are stored for the period necessary for the performance, termination or expiry in another way of the concluded Sales Agreement or agreement for the provision of Electronic Services.
Direct marketing	Article 6(1)(f) of the GDPR Regulation (legitimate interest of the controller) – processing is necessary for the purposes of the legitimate interests of the Controller consisting in caring for the interests and good image of the Controller, its Online Store and striving to sell Products	Data are stored for the period of the existence of the legitimate interest pursued by the Controller, but no longer than for the period of limitation of the Controller's claims against the data subject from the title of the business activity conducted by the Controller. The limitation period is determined by law, in particular the Civil Code (the basic limitation period for claims related to conducting business activity is three years, and for a sales agreement two years). The Controller cannot process data for the purpose of direct marketing in the event of an effective objection in this regard by the data subject.
Marketing	Article 6(1)(a) of the GDPR Regulation (consent) – the data subject has given consent to the processing of their personal data for marketing purposes by the Controller	Data are stored until the withdrawal of consent by the data subject for further processing of their data for this purpose.
Expressing an opinion by the Client about the concluded Sales Agreement	Article 6(1)(a) of the GDPR Regulation – the data subject has given consent to the processing of their personal data for the purpose of expressing an opinion	Data are stored until the withdrawal of consent by the data subject for further processing of their data for this purpose.
Keeping accounting books	Article 6(1)(c) of the GDPR Regulation in connection with Art. 74(2) of the Accounting Act, i.e. from January 30, 2018 (Journal of Laws of 2018, item 395) – processing is necessary for compliance with a legal obligation to which the Controller is subject	Data are stored for the period required by law ordering the Controller to store accounting books (5 years, counting from the beginning of the year following the financial year to which the data relate).
Establishment, pursuit or defense of claims which the Controller may raise or which may be raised against the Controller	Article 6(1)(f) of the GDPR Regulation (legitimate interest of the controller) – processing is necessary for the purposes of the legitimate interests of the Controller consisting in the establishment, pursuit or defense of claims which the Controller may raise or which may be raised against the Controller	Data are stored for the period of existence of the legitimate interest pursued by the Controller, but no longer than for the period of limitation of claims that may be raised against the Controller (the basic limitation period for claims against the Controller is six years).
Using the Online Store website and ensuring its proper operation	Article 6(1)(f) of the GDPR Regulation (legitimate interest of the controller) – processing is necessary for the purposes of the legitimate interests of the Controller consisting in conducting and maintaining the Online Store website	Data are stored for the period of the existence of the legitimate interest pursued by the Controller, but no longer than for the period of limitation of the Controller's claims against the data subject from the title of the business activity conducted by the Controller.
Keeping statistics and traffic analysis in the Online Store	Article 6(1)(f) of the GDPR Regulation (legitimate interest of the controller) – processing is necessary for the purposes of the legitimate interests of the Controller consisting in keeping statistics and traffic analysis in the Online Store to improve the functioning of the Online Store and increase sales of Products	Data are stored for the period of the existence of the legitimate interest pursued by the Controller, but no longer than for the period of limitation of the Controller's claims against the data subject from the title of the business activity conducted by the Controller.

4. DATA RECIPIENTS IN THE ONLINE STORE

4.1. For the proper functioning of the Online Store, including for the implementation of concluded Sales Agreements, it is necessary for the Controller to use the services of external entities (such as e.g. a software provider, courier, or an entity processing payments). The Controller uses only the services of such processors who provide sufficient guarantees to implement appropriate technical and organizational measures so that the processing meets the requirements of the GDPR Regulation and protects the rights of data subjects.

4.2. Transfer of data by the Controller does not occur in every case and not to all recipients or categories of recipients indicated in the privacy policy – the Controller transfers data only when it is necessary to achieve a given purpose of personal data processing and only to the extent necessary to achieve it. For example, if the Client uses personal collection, their data will not be transferred to the carrier cooperating with the Controller.

4.3. Personal data of Service Recipients and Clients of the Online Store may be transferred to the following recipients or categories of recipients:

4.3.1. carriers / forwarders / courier brokers / entities operating the warehouse and/or shipping process – in the case of a Client who uses the delivery method of the Product in the Online Store via postal shipment or courier shipment, the Controller provides the collected personal data of the Client to the selected carrier, forwarder or intermediary performing shipments on behalf of the Controller, and if the shipment takes place from an external warehouse – to the entity operating the warehouse and/or shipping process to the extent necessary to complete the delivery of the Product to the Client.

4.3.2. service providers supplying the Controller with technical, IT and organizational solutions, enabling the Controller to conduct business activity, including the Online Store and Electronic Services provided through it (in particular providers of computer software for running the Online Store, e-mail and hosting providers and providers of management software and technical support for the Controller) – the Controller provides the collected personal data of the Client to the selected provider acting on its behalf only in the case and to the extent necessary to achieve a given purpose of data processing consistent with this privacy policy.

4.3.3. providers of accounting, legal and advisory services providing the Controller with accounting, legal or advisory support (in particular an accounting office, law firm or debt collection company) – the Controller provides the collected personal data of the Client to the selected provider acting on its behalf only in the case and to the extent necessary to achieve a given purpose of data processing consistent with this privacy policy.

5. PROFILING IN THE ONLINE STORE

5.1. The GDPR Regulation imposes an obligation on the Controller to inform about automated decision-making, including profiling referred to in Art. 22 para. 1 and 4 of the GDPR Regulation, and at least in these cases significant information about the rules of their taking, as well as about the meaning and predicted consequences of such processing for the data subject. Having this in mind, the Controller provides information in this point of the privacy policy regarding possible profiling.

5.2. The Controller does not use profiling in the Online Store.

6. RIGHTS OF THE DATA SUBJECT

6.1. Right of access, rectification, restriction, erasure or portability – the data subject has the right to request access to their personal data from the Controller, their rectification, erasure ("right to be forgotten") or restriction of processing and has the right to object to processing, as well as has the right to portability of their data. Detailed conditions for exercising the rights indicated above are set out in Art. 15–21 of the GDPR Regulation.

6.2. Right to withdraw consent at any time – a person whose data is processed by the Controller on the basis of given consent (on the basis of Art. 6 para. 1 lit. a) or Art. 9 para. 2 lit. a) of the GDPR Regulation), then they have the right to withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

6.3. Right to lodge a complaint with a supervisory authority – the person whose data is processed by the Controller 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 Act on the Protection of Personal Data. 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 based on Art. 6 para. 1 lit. e) (public interest or tasks) or f) (legitimate interest of the controller), including profiling based on those provisions. The Controller shall in such case no longer process these personal data, unless it demonstrates compelling legitimate grounds for processing which override the interests, rights and freedoms of the data subject, or grounds for the establishment, pursuit or defense of 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, including profiling, to the extent that processing is related to such direct marketing.

6.6. In order to exercise the rights referred to in this point of the privacy policy, one may contact the Controller by sending an appropriate message in writing or by e-mail to the Controller's address indicated at the beginning of the privacy policy or by using the contact form available on the Online Store website.

7. COOKIES IN THE ONLINE STORE AND ANALYTICS

7.1. Cookies are small textual information in the form of text files, sent by the server and saved on the side of the person visiting the Online Store website (e.g. on the hard drive of a computer, laptop, or on the smartphone's memory card – depending on which device the visitor of our Online Store uses). Detailed information regarding Cookies, as well as the history of their creation, can be found e.g. here: https://pl.wikipedia.org/wiki/HTTP_cookie.

7.2. The Controller makes available on the Online Store website a tool for easy and active management of Cookies available after the first entry to the Online Store website, and then available in the footer on the Online Store website. Active management allows, among other things, checking which Cookies are or can be saved while using the Online Store website, as well as selecting and subsequently changing the scope and purposes of using Cookies in relation to the device and the person visiting the Online Store website.

7.3. The Controller provides, in this Privacy Policy, a range of information regarding the use of Cookies on the Online Store's website, including their types and purposes, as well as the management thereof using, for example, the settings of a web browser and/or a Cookies management tool available on the Online Store's website. The Controller encourages the use of the Cookies management tool available on the Online Store's website, which enables users to easily and actively manage Cookies while using the Online Store's website. If such a tool is not available, users are encouraged to review the information provided below, including information concerning the management of Cookies through the settings of a web browser.

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

Due to their provider	Due to their storage period on the device of the person visiting the Online Store website	Due to the purpose of their use
1) own (created by the Controller's Online Store website) and 2) belonging to third parties (other than the Controller).	1) session (stored until logging out from the Online Store or turning off the web browser) and 2) permanent (stored for a specified time, defined by the parameters of each file or until manual deletion).	1) necessary (enabling the proper functioning of the Online Store website), 2) functional/preferential (enabling the adjustment of the Online Store website to the preferences of the visitor), 3) analytical and performance (collecting information on how the Online Store website is used), 4) marketing, advertising and social (collecting information about the person visiting the Online Store website for the purpose of displaying advertisements, their personalization, measuring effectiveness and conducting other marketing activities including on websites separate from the Online Store website).

7.5. The Controller may process data contained in Cookies while visitors use the Online Store website for the following specific purposes:

Purposes of the use of Cookies in the Controller's Online Store
identification of Service Recipients as logged in to the Online Store and showing that they are logged in (necessary Cookies)
remembering Products added to the cart in order to place an Order (necessary Cookies)
remembering data from filled out Order Forms, surveys or login data to the Online Store (necessary and/or functional/preferential Cookies)
adjusting the content of the Online Store website to the individual preferences of the Service Recipient and optimization of using the Online Store websites (functional/preferential Cookies)
conducting anonymous statistics showing the way the Online Store website is used (analytical and performance Cookies)
displaying and rendering advertisements, limiting the number of advertisement displays and ignoring advertisements that the Service Recipient does not want to see, measuring the effectiveness of advertisements, as well as personalization of advertisements (marketing, advertising and social Cookies)

7.6. Checking which Cookies are currently sent by the Online Store website is possible, regardless of the web browser, using tools available e.g. at: https://www.cookiemetrix.com or https://www.cookie-checker.com.

7.7. Standardly, most web browsers available on the market accept saving Cookies by default. Everyone has the possibility to determine the conditions for using Cookies using the settings of their own web browser. This means that you can, for example, partially limit (e.g. temporarily) or completely disable the option of saving Cookies – in the latter case, however, this may affect some functionalities of the Online Store (for example, it may prove impossible to go through the Order path via the Order Form due to not remembering Products in the cart during subsequent steps of placing the Order).

7.8. Web browser settings in the scope of Cookies are important from the point of view of consent to the use of Cookies by our Online Store – according to the regulations, such consent can also be expressed through the web browser settings. Detailed information on changing settings regarding Cookies and on deleting them independently in the most popular web browsers is available in the help section of the web browser and on the following websites:

7.9. The Controller may use the Google Analytics and Universal Analytics services in the Online Store, provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). These services assist the Controller in compiling statistics and analysing traffic within the Online Store. The data collected within the scope of the aforementioned services are processed in order to generate statistics that support the administration of the Online Store and the analysis of traffic within the Online Store. Such data are of an aggregated nature. By using the above-mentioned services in the Online Store, the Controller collects data such as the sources and medium through which visitors access the Online Store, the manner in which they behave on the Online Store's website, information regarding the devices and browsers used to access the website, as well as the IP address and domain, geographical data and demographic data (age, gender) and interests.

7.10. It is possible to easily block the sharing of information about activity on the Online Store website to Google Analytics by a given person – for this purpose, you 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 possibility of the Controller using advertising and analytical services provided by Google Ireland Ltd. in the Online Store, the Controller indicates that full information on the principles of processing data of persons visiting the Online Store 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.

7.12. The Controller may use the Meta Pixel service in the Online Store provided by Meta Platforms Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland). This service helps the Controller measure the effectiveness of advertisements and find out what actions visitors to the Online Store are taking, as well as display tailored advertisements to these persons. Detailed information about the operation of the Meta Pixel can be found at the following internet address: https://www.facebook.com/business/help/742478679120153?helpref=page_content.

7.13. Management of the Meta Pixel operation is possible through advertisement settings in one's account on Facebook.com: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen.

8. FINAL PROVISIONS

8.1. The Online Store may contain links to other websites. The Controller encourages you, after going to other sites, to familiarize yourself with the privacy policy established there. This privacy policy applies only to the Controller's Online Store.