PRIVACY POLICY OF THE SKLEJKAORZECHOWO.PL WEBSITE

GENERAL PROVISIONS

This privacy policy of the Website is for informational purposes, which means that it does not constitute any obligation for persons using the Website. The privacy policy contains primarily the rules regarding the processing of personal data collected by the Administrator on the Website, including the basis, purposes and period of personal data processing and the rights of data subjects, as well as information regarding the use of Cookies and similar technologies on the Website and analytical tools.

The administrator of personal data collected via the Website is SKLEJKA ORZECHOWO SPÓŁKA AKCYJNA with its registered office in Orzechowo (registered office and delivery address: ul. Miłosławska 13, 62-322 Orzechowo); entered into the Register of Entrepreneurs of the National Court Register under the KRS number: 0000491363; registry court where the company's documentation is kept: District Court Poznań - Nowe Miasto and Wilda in Poznań, 9th Commercial Division of the National Court Register; share capital in the amount of: PLN 57,500,000.00 (fully paid); NIP: 7890001711; REGON: 000122973; e-mail address: sekretariat@sklejkaorzechowo.pl and contact telephone number: 61-435-11-00
– hereinafter referred to as "Administrator” and who is also the Owner of the Website.

Personal data on the Website are 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 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 repealing Directive 95/46/EC (General Regulation
on data protection) - 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.

Use of the Website is voluntary. Similarly, the provision of personal data by the user using the Website is voluntary, with the proviso that failure to provide specific data required to use a specific functionality of the Website by the user may result in the inability to use this functionality (e.g. contact form). In such a case, providing personal data is a contractual requirement and if the data subject wants to use a specific functionality provided on the Website by the Administrator, he or she is obliged to provide the required data. Each time, the scope of data required to use the functionality of the Website is indicated by the Administrator on the Website (e.g. before filling out the contact form).

The Administrator takes special care to protect the interests of persons whose personal data he processes, and in particular he is responsible and ensures that the data collected by him are: (1) processed in accordance with the law; (2) collected for specified lawful purposes and not subjected to further processing that is incompatible with those purposes; (3) substantively 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 to achieve the purpose of processing, and (5) processed in a way 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 means.

Taking into account the nature, scope, context and purposes of processing as well as the risk of violating the rights and freedoms of natural persons with varying probability and severity of threat, the Administrator implements appropriate technical and organizational measures to ensure that processing takes place in accordance with the GDPR Regulation and to be able to demonstrate this. These measures are reviewed and updated as necessary. The Administrator uses technical measures to prevent unauthorized persons from obtaining and modifying personal data sent electronically.

All words, expressions and acronyms appearing in this privacy policy and beginning with a capital letter should be understood in accordance with their meaning arising from this document.

BASIS OF DATA PROCESSING

The administrator is entitled to process personal data in cases where - and to the extent
in which - at least one of the following conditions is met: (1) the data subject has consented to the processing of his or her 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 to take steps at the request of the data subject before concluding the contract; (3) processing is necessary to fulfill the legal obligation imposed on the Administrator; 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 , especially when that person is a child.

The processing of personal data by the Administrator requires at least one occurrence each time
from the grounds indicated above. The specific grounds for processing personal data of Website users by the Administrator are indicated in the next point of the privacy policy - in relation to the given purpose of processing personal data by the Administrator.

PURPOSE, BASIS AND PERIOD OF DATA PROCESSING ON THE WEBSITE

Each time, the purpose, basis and period as well as the recipients of personal data processed by the Administrator are specified
from actions undertaken by a given user on the Website.

The Administrator may process personal data on the Website for the following purposes, on the following grounds and for the period in accordance with the table below:

Purpose of data processing	Legal basis for data processing	Data storage period
Using electronic services made available by the Administrator on the Website	Article 6(1) 1 letter b) GDPR Regulations (performance of the contract) - processing is necessary to perform the contract to which the data subject is a party, or to take action at the request of the data subject before concluding the contract, such as answering the inquiry sent by the user via the contact form	The data is stored for the period necessary to perform, terminate or otherwise expire the contract concluded with the Administrator, e.g. for the time needed to provide the user with an answer to the inquiry sent via the contact form.
direct marketing	Article 6(1) 1 letter f) GDPR Regulations (legitimate interest of the administrator) - processing is necessary for purposes arising from the legitimate interests of the Administrator - consisting in taking care of the interests and good image of the Administrator and striving to provide services	The data is stored for the duration of the legally justified interest pursued by the Administrator, but no longer than the limitation period for claims against the data subject arising from the business activities conducted by the Administrator. The limitation period is determined by legal provisions, in particular the Civil Code (the basic limitation period for claims related to running a business is three years). The administrator may not process data for direct marketing purposes if the data subject expresses an effective objection in this regard.
Bookkeeping	Article 6(1) 1 letter c) GDPR Regulations in connection with joke. 74 section 2 of the Accounting Act, i.e. of January 30, 2018 (Journal of Laws of 2018, item 395, as amended) - processing is necessary to fulfill the legal obligation imposed on the Administrator	The data is stored for the period required by law requiring the Administrator to store accounting books (5 years from the beginning of the year following the financial year to which the data relates).
Marketing	Article 6(1) 1 letter a) GDPR Regulations (consent) - the data subject has consented to the processing of his or her personal data for marketing purposes by the Administrator	The data is stored until the data subject withdraws his or her consent to further processing of his or her data for this purpose.
Determining, pursuing or defending claims that may be raised by the Administrator or that may be raised against the Administrator	Article 6(1) 1 letter f) GDPR Regulations - processing is necessary for purposes arising from the legitimate interests of the Administrator - consisting in determining, pursuing or defending claims that may be raised by the Administrator or that may be raised against the Administrator	The data is stored for the duration of the legally justified interest pursued by the Administrator, but no longer than the limitation period for claims against the data subject arising from the business activities conducted by the Administrator. The limitation period is determined by the provisions of law, in particular the Civil Code (the basic limitation period for claims that may be raised against the Administrator is six years).
Using the Website and ensuring its proper operation	Article 6(1) 1 letter f) GDPR Regulations (legitimate interest of the administrator) - processing is necessary for the purposes arising from the legitimate interests of the Administrator - consisting in running and maintaining the Website	The data is stored for the duration of the legally justified interest pursued by the Administrator, but no longer than the period of limitation of the Administrator's claims against the data subject in connection with the business activity conducted by the Administrator. The limitation period is determined by legal provisions, in particular the Civil Code (the basic limitation period for claims related to running a business is three years).
Keeping statistics and analyzing traffic on the Website	Article 6(1) 1 letter f) GDPR Regulations (legitimate interest of the administrator) - processing is necessary for the purposes arising from the legitimate interests of the Administrator - consisting in conducting statistics and analyzing traffic on the Website in order to improve the functioning of the Website	The data is stored for the duration of the legally justified interest pursued by the Administrator, but no longer than the period of limitation of the Administrator's claims against the data subject in connection with the business activity conducted by the Administrator. The limitation period is determined by legal provisions, in particular the Civil Code (the basic limitation period for claims related to running a business is three years).

RECIPIENTS OF DATA ON THE WEBSITE

For the proper functioning of the Website, it is necessary for the Administrator to use the services of external entities (such as, for example, a software supplier). The Administrator only uses the services of such processors who provide sufficient guarantees of implementing appropriate technical and organizational measures so that the processing meets the requirements of the GDPR and protects the rights of data subjects.

Personal data may be transferred by the Administrator to a third country, and the Administrator ensures that in such a case it will be done in relation to a country ensuring an adequate level of protection - in accordance 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 his or her data. The Administrator transfers the collected personal data only in the case and to the extent necessary to achieve the given purpose of data processing in accordance with this privacy policy.

Data is not transferred by the Administrator 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 purpose of personal data processing and only to the extent necessary to achieve it.

Personal data of users of the Website may be transferred to the following recipients or categories of recipients:

service providers supplying the Administrator with technical, IT and organizational solutions enabling the Administrator to conduct business activities, including its Website and electronic services (in particular suppliers of computer software for running the Website, e-mail and hosting providers and suppliers of software for managing the company and providing technical assistance to the Administrator) - the Administrator provides the collected personal data of the user to a selected supplier acting on his behalf only in the case and to the extent necessary to complete a given purpose of data processing in accordance with this privacy policy.
providers of social plug-ins, scripts and other similar tools placed on the Website that enable the browser of a person visiting the Website to download content from the providers of the said plug-ins (e.g. logging in using social media login details) and transmitting the visitor's personal data to these providers for this purpose, including:
- LinkedIn Ireland Unlimited Company - the Administrator uses Linkedin.com social plug-ins on the Online Store website and therefore collects and shares personal data of the Service User using the Online Store website to LinkedIn Ireland Unlimited Company (Gardner House, 2 Wilton Pl, Saint Peter's, Dublin 2, Ireland ) to the extent and in accordance with the privacy principles available here: https://www.linkedin.com/legal/privacy-policy?trk=homepage-basic_footer-privacy-policy (this data includes information about activities on the Online Store website - including information about the device, visited websites, purchases, displayed advertisements and how to use the services - regardless of whether the Service User has an account on Linkedin.com or is logged in to it).
- Meta Platforms Ireland Ltd. – The Administrator uses social plug-ins from Facebook on the Online Store website (e.g. the Like button, Share button or logging in using Facebook login details) and Instagram and therefore collects and shares personal data of the Service Recipient using the Online Store website to 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 - in the case of Facebook - here: https://www.facebook.com/about/privacy/ and - in case of Instagram - here: https://help.instagram.com/519522125107875/?helpref=hc_fnav (this data includes information about activities on the Online Store website - including information about the device, websites visited, purchases, displayed advertisements and how to use services - regardless of whether the Service User has a Facebook or Instagram account and is logged in to Facebook or Instagram).

PROFILING

The GDPR requires the Administrator to provide information about automated decision-making, including profiling, as referred to in Art. 22 section 1 and 4 of the GDPR, and - at least in these cases - important information about the principles of their implementation, as well as the importance and expected 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.

The Administrator may use profiling on the Website for direct marketing purposes, but decisions made on its basis by the Administrator do not concern the conclusion or refusal to conclude a contract or the possibility of using electronic services on the Website. Despite profiling, a given person can freely decide whether he or she wants to take advantage of the discount obtained in this way or the Administrator's offer.

Profiling on the Website may consist in automatic analysis or forecast of a given person's behavior on the Website, e.g. by analyzing the previous history of activity on the Website. The condition for such profiling is that the Administrator has the personal data of a given person in order to be able to send him, for example, a discount code or an offer.

The data subject has the right not to be subject to a decision which is based solely on automated processing, including profiling, and which produces legal effects concerning him or her or similarly significantly affects him or her.

RIGHTS OF THE DATA SUBJECT

Right of access, rectification, restriction, deletion or transfer – the data subject has the right to request from the Administrator access to his or her personal data, rectification, deletion ("right to be forgotten") or restriction of processing and the right to object to the processing, and also has the right to transfer his or her data . Detailed conditions for exercising the above-mentioned rights are indicated in Art. 15-21 of the GDPR Regulations.

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

The right to lodge a complaint with the supervisory authority – the person whose data is processed by the Administrator has the right to lodge a complaint with the supervisory authority in the manner and manner 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.

Right to object – the data subject has the right to object at any time –
for reasons related to her particular situation - in relation to the processing of personal data concerning her based on Art. 6 section 1 letter e) (public interest or tasks) or f) (legitimate interest of the administrator), including profiling based on these provisions. In such a case, the Administrator is no longer allowed to process this personal data, unless he demonstrates the existence of valid legally justified grounds for processing, overriding the interests, rights and freedoms of the data subject, or grounds for establishing, pursuing or defending claims.

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 the processing of personal data concerning him or her for the purposes of such marketing, including profiling, to the extent that the processing is related to such marketing. direct.

In order to exercise the rights referred to in this point of the privacy policy, you can contact the Administrator by sending an appropriate message in writing or by e-mail to the Administrator's address indicated at the beginning of the privacy policy.

COOKIES ON THE WEBSITE AND ANALYTICS

Cookies are small text information in the form of text files, sent by the server and saved on the side of the person visiting the Website (e.g. on the hard drive of a computer, laptop or on the memory card of a smartphone - depending on the device used). visitors to our Website). Detailed information on cookies, as well as the history of their creation, can be found, among others, at: here: https://pl.wikipedia.org/wiki/HTTP_cookie.

Cookies that may be sent by the Website can be divided into different types according to the following criteria:

Because of their supplier:

1) own (created by the Administrator's Website) and

2) belonging to third parties/entities (other than the Administrator)

Due to their storage period on the device of the person visiting the Website:

1) session cookies (stored until you leave the Website or turn off your web browser) and

2) permanent (stored for a specific period of time, defined by the parameters of each file, or until manually deleted)

Due to the purpose of their use:

1) necessary (enabling the proper functioning of the Website),

2) functional/preferential (enabling adapting the Website to the preferences of the person visiting the website),

3) analytical and performance (collecting information about how the Website is used),

4) marketing, advertising and social media (collecting information about a person visiting the Website in order to display advertisements to that person, personalize them, measure effectiveness and conduct other marketing activities, including on websites separate from the Website, such as social networking sites or other websites belonging to the same advertising networks as the Website)

The Administrator may process data contained in Cookies when visitors use the Website for the following specific purposes:

Purposes of using cookies on the Administrator's website	remembering data from completed forms (necessary and/or functional/preferential cookies)
	adapting the content of the Website to individual user preferences (e.g. regarding colors, font size, page layout) and optimizing the use of the Website (functional/preference cookies)
	keeping anonymous statistics showing how the Website is used (analytical and performance cookies)

It is possible to check in the most popular web browsers what Cookies (including the period of operation of Cookies and their provider) that are currently being sent by the Website in the following way:

In Chrome: (1) in the address bar, click the lock icon on the left, (2) go to the "Cookies" tab.	In Firefox: (1) in the address bar, click the shield icon on the left, (2) go to the "Allowed" or "Blocked" tab, (3) click the "Cross-site tracking cookies", "Social networking trackers" or "Content from "tracking elements"	In Internet Explorer: (1) click the "Tools" menu, (2) go to the "Internet Options" tab, (3) go to the "General" tab, (4) go to the "Settings" tab, (5) click the "View Files" box
In the Opera browser: (1) in the address bar, click the lock icon on the left, (2) go to the "Cookies" tab.	in Safari browser: (1) click the "Preferences" menu, (2) go to the "Privacy" tab, (3) click the "Manage website data" box	Regardless of the browser, using tools available, e.g. on the website: https://www.cookiemetrix.com/ or: https://www.cookie-checker.com/

By default, most web browsers available on the market accept cookies. Everyone can define the conditions for the use of 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 ability to save cookies - in the latter case, however, it may affect some functionalities of the Website.

Internet browser settings regarding cookies are important from the point of view of consent to use
from Cookies via our Website - in accordance with the regulations, such consent may also be expressed through the settings of the web browser. Detailed information on changing Cookie settings and deleting them yourself in the most popular web browsers is available in the browser's help section and on the following websites (just click on the link):

in the Chrome browser

in Firefox

in Internet Explorer

in the Opera browser

in Safari browser

in Microsoft Edge browser

The Administrator may use the following services on the Website:

Google Analytics (GA4) provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). These services help the Administrator conduct statistics and analyze traffic on the Website. The collected data is processed as part of the above services to generate statistics helpful in administering the Website and analyzing traffic on the Website. This data is aggregated. Using the above services on the Website, the Administrator collects data such as the sources and medium of obtaining visitors to the Website and how they behave on the Website, information about devices
and browsers from which they visit the website, IP and domain, geographical data and demographic data (age, gender) and interests.

It is possible for a given person to easily block information about their activity on the Website from being made available to Google Analytics - 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.

Due to the possibility for the Administrator to use advertising and analytical services provided by Google Ireland Ltd. on the Website, the Administrator indicates that full information on the principles of processing data of persons visiting the Website (including information saved in Cookies) by Google Ireland Ltd. can be found in the privacy policy of Google services available at: https://policies.google.com/technologies/partner-sites.

Meta Pixel provided by Meta Platforms Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland). This service helps the Administrator measure the effectiveness of advertisements and find out what actions are taken by visitors to the online store, as well as display tailored advertisements to these people.

You can manage the operation of Meta Pixel through the ad settings in your Facebook.com account: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen.

Due to the possibility for the Administrator to use advertising and analytical services provided by Meta Platforms Ireland Limited in the Online Store, the Administrator indicates that full information on the principles of processing data of persons visiting the Online Store (including information saved in Cookies) by Meta Platforms Ireland Limited can be found in the privacy policy of Meta services available at: https://www.facebook.com/privacy/policy/?entry_point=facebook_help_center_ig_data_policy_redirect.

Website Privacy Policy