Privacy Policy – Topool – Praise The Sun

PRIVACY POLICY

ONLINE STORE topool.eu

TABLE OF CONTENTS:

GENERAL PROVISIONS
BASES FOR DATA PROCESSING
PURPOSE, BASIS AND PERIOD OF DATA PROCESSING IN THE ONLINE STORE
RECIPIENTS OF DATA IN THE ONLINE STORE
PROFILING IN THE ONLINE STORE
RIGHTS OF THE PERSON WHOSE DATA CONCERN
COOKIES IN THE ONLINE STORE AND ANALYTICS
FINAL PROVISIONS

GENERAL PROVISIONS

This privacy policy of the Online Store is for informational purposes only, which means it does not create any obligations for the Service Recipients or Customers of the Online Store. The privacy policy outlines the principles regarding the processing of personal data by the Administrator in the Online Store, including the basis, purposes, and duration of personal data processing as well as the rights of individuals whose data is processed. It also includes information about the use of Cookies and analytical tools in the Online Store.
The Administrator of personal data collected via the Online Store is Renovey sp. z o.o. conducting business under the name RENOVEY SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ, registered in the National Court Register maintained by the minister competent for economic affairs, with the following details: business address and address for service: ul. Dworska 34, 18-230 Ciechanowiec, NIP 5252821058, REGON 385934253, KRS 0000838010, email address: biuro@topool.eu, phone number: 539303006 – referred to as the “Administrator,” who is also the Service Provider of the Online Store and the Seller.
Personal data in the Online Store is processed by the Administrator in accordance with the applicable laws, particularly with the Regulation of the European Parliament and of the Council (EU) 2016/679 of 27 April 2016 on the protection of natural persons concerning the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) – 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
Using the Online Store, including making purchases, is voluntary. Similarly, providing personal data by a Service Recipient or Customer using the Online Store is voluntary, with two exceptions: (1) entering into contracts with the Administrator – failure to provide, in cases and within the scope indicated on the Online Store’s website and in the Online Store Regulations and this privacy policy, personal data necessary to conclude and execute a Sales Agreement or an Electronic Service agreement with the Administrator will result in an inability to conclude this agreement. Providing personal data is a contractual requirement, and if a person concerned wishes to enter into an agreement with the Administrator, they are obligated to provide the required data. The scope of data required to conclude an agreement is specified each time on the Online Store’s website and in the Online Store Regulations; (2) statutory obligations of the Administrator – providing personal data is a legal requirement arising from universally binding legal provisions imposing on the Administrator the obligation to process personal data (e.g., processing data to maintain tax or accounting records), and failure to provide it will prevent the Administrator from fulfilling these obligations.
The Administrator takes special care to protect the interests of individuals whose personal data is processed, ensuring that collected data is: (1) processed legally; (2) collected for specified, legal purposes and not subject to further processing incompatible with those purposes; (3) factually correct and adequate in relation to the purposes for which it is processed; (4) stored in a form allowing the identification of individuals concerned, no longer than necessary to achieve the purpose of processing; and (5) processed in a manner ensuring appropriate security of personal data, including protection against unauthorized or unlawful processing and accidental loss, destruction, or damage, through appropriate technical or organizational measures.
Considering the nature, scope, context, and purposes of processing as well as the risk of varying likelihood and severity of threats to the rights or freedoms of natural persons, the Administrator implements appropriate technical and organizational measures to ensure processing is carried out in accordance with this regulation and to be able to demonstrate compliance. These measures are reviewed and updated as necessary. The Administrator uses technical measures to prevent unauthorized persons from acquiring and modifying personal data sent electronically.
All words, expressions, and acronyms present in this privacy policy and beginning with a capital letter (e.g., Seller, Online Store, Electronic Service) should be understood in accordance with their definition contained in the Online Store Regulations available on the Online Store’s website.

2. BASIS FOR DATA PROCESSING

The Administrator is authorized to process personal data when – and to the extent that – at least one of the following conditions is met: (1) the data subject has consented to the processing of their personal data for one or more specific purposes; (2) processing is necessary for the performance of a contract to which the data subject is a party or to take action at the request of the data subject prior to entering into a contract; (3) processing is necessary for compliance with a legal obligation to which the Administrator is subject; or (4) processing is necessary for the purposes of the legitimate interests pursued by the Administrator or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data, particularly when the data subject is a child.
Processing of personal data by the Administrator requires that at least one of the bases listed in point 2.1 of the privacy policy exists. The specific bases for processing personal data by the Administrator, in relation to the specific purpose of data processing, are stated in the next point of the privacy policy.

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

The purpose, basis, and duration, as well as recipients of personal data processed by the Administrator, derive from the actions undertaken by a given Service Recipient or Customer in the Online Store or by the Administrator.
The Administrator may process personal data within the Online Store for the following purposes, on the bases and within the time frames indicated in the table below:

The purpose of data processing	Legal basis for data processing	Data storage period
Execution of the Sales Agreement or the agreement for the provision of Electronic Services or taking action at the request of the data subject before concluding the above-mentioned agreements	Article 6(1)(b) of the GDPR Regulation (performance of a contract) – processing is necessary for the performance of a contract to which the data subject is a party, or to take steps at the request of the data subject before entering into a contract	The data is stored for the period necessary to execute, terminate or otherwise expire the concluded Sales Agreement or the agreement for the provision of Electronic Services.
Direct Marketing	Article 6 section 1 letter f) of the GDPR Regulation (legitimate interest of the administrator) – processing is necessary for the purposes resulting from the legitimate interests of the Administrator – consisting in taking care of the interests and good image of the Administrator, its Online Store and striving to sell Products	Data is stored for the duration of the legitimate interest pursued by the Administrator, but no longer than the limitation period for the Administrator’s claims against the data subject, resulting from the business activity conducted by the Administrator. The limitation period is specified by law, in particular the Civil Code (the basic limitation period for claims related to conducting business activity is three years, and for the Sales Agreement two years). The Administrator may not process data for direct marketing purposes in the event of an effective objection in this respect by the data subject.
Marketing	Article 6(1)(a) of the GDPR Regulation (consent) – the data subject has consented to the processing of his or her personal data for marketing purposes by the Controller	The data is stored until the data subject withdraws consent to further processing of his or her data for this purpose.
The Customer’s expression of opinion on the concluded Sales Agreement	Article 6(1)(a) of the GDPR Regulation – the data subject has consented to the processing of his or her personal data for the purpose of expressing an opinion	The data is stored until the data subject withdraws consent to further processing of his or her data for this purpose.
Tax bookkeeping	Article 6 section 1 letter c) of the GDPR Regulation in connection with Article 86 § 1 of the Tax Ordinance Act of 17 January 2017 (Journal of Laws of 2017, item 201, as amended) – processing is necessary to fulfil the legal obligation of the Administrator	Data is stored for the period required by law requiring the Administrator to store tax books (until the expiry of the limitation period for the tax liability, unless tax laws provide otherwise)
Determining, pursuing or defending claims that may be raised by the Administrator or that may be raised against the Administrator	Article 6 paragraph 1 letter f) of the GDPR Regulation (legitimate interest of the administrator) – processing is necessary for the purposes resulting 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 legitimate interest pursued by the Administrator, but no longer than the limitation period for claims that may be brought against the Administrator (the basic limitation period for claims against the Administrator is six years).
Using the Online Store website and ensuring its proper operation	Article 6 paragraph 1 letter f) of the GDPR Regulation (legitimate interest of the administrator) – processing is necessary for the purposes resulting from the legitimate interests of the Administrator – consisting in running and maintaining the Online Store website	Data is stored for the duration of the legitimate interest pursued by the Administrator, but no longer than the limitation period for the Administrator’s claims against the data subject, resulting from the Administrator’s business activity. The limitation period is specified by law, in particular the Civil Code (the basic limitation period for claims related to business activity is three years, and for the Sales Agreement two years).
Maintaining statistics and analyzing traffic in the Online Store	Article 6 section 1 letter f) of the GDPR Regulation (legitimate interest of the administrator) – processing is necessary for the purposes resulting from the legitimate interests of the Administrator – consisting in keeping statistics and analyzing traffic in the Online Store in order to improve the functioning of the Online Store and increase sales of Products	Data is stored for the duration of the legitimate interest pursued by the Administrator, but no longer than the limitation period for the Administrator’s claims against the data subject, resulting from the Administrator’s business activity. The limitation period is specified by law, in particular the Civil Code (the basic limitation period for claims related to business activity is three years, and for the Sales Agreement two years).

4. RECIPIENTS OF DATA IN THE ONLINE STORE

For the proper functioning of the Online Store, including the execution of Sales Agreements, it is necessary for the Administrator to use the services of external entities (such as software providers, couriers, or payment processors). The Administrator uses only those processors who provide sufficient guarantees of implementing appropriate technical and organizational measures to ensure that 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, ensuring that it is to a country that provides an adequate level of protection in accordance with the GDPR. If transferred to other countries, it will be done based on standard data protection clauses. The Administrator ensures that the data subject has the right to obtain a copy of their data. The Administrator only shares collected personal data when necessary for achieving the specific processing purpose aligned with this privacy policy.
Data transfer by the Administrator does not occur in every case or to all recipients or categories of recipients mentioned in this privacy policy. The Administrator only transfers data when necessary for achieving a specific purpose of personal data processing and only to the extent required. Personal data of Service Recipients and Customers of the Online Store may be shared with the following recipients or categories of recipients:

Carriers / forwarders / courier brokers / entities handling the warehouse and/or shipping process – in the case of a Customer who uses the delivery method through postal or courier shipment, the Administrator shares collected personal data of the Customer with the selected carrier, forwarder, or intermediary conducting shipments on behalf of the Administrator, and if the shipment occurs from an external warehouse, with the entity handling the warehouse and/or shipment process, only to the extent necessary to deliver the Product to the Customer.
Entities processing electronic or card payments – in the case of a Customer who uses electronic or card payment methods in the Online Store, the Administrator shares the Customer’s collected personal data with the chosen entity processing these payments in the Online Store on behalf of the Administrator, only to the extent necessary to handle payments made by the Customer.
Providers of survey systems – in the case of a Customer who has agreed to give feedback on the concluded Sales Agreement, the Administrator shares the collected personal data of the Customer with the selected entity providing the survey system for the concluded Sales Agreements in the Online Store on behalf of the Administrator, only to the necessary extent for the Customer to provide feedback using the survey system.
Service providers supplying the Administrator with technical, IT, and organizational solutions that enable the Administrator to conduct business activities, including the Online Store and the Electronic Services provided via the Store (specifically software providers for the Online Store, email and hosting providers, and software providers supporting company management and technical support for the Administrator) – the Administrator shares collected personal data of the Customer with a selected supplier acting on his behalf only in cases and to the extent necessary to achieve the specific data processing purposes compliant with this privacy policy.
Providers of accounting, legal, and advisory services providing the Administrator with accounting, legal, or advisory support (in particular accounting offices, legal offices, or debt collection companies) – the Administrator shares collected personal data of the Customer with a selected supplier acting on his behalf only when necessary and to the extent required for achieving the specific data processing purposes compliant with this privacy policy.

5. PROFILING IN THE ONLINE STORE

The GDPR imposes an obligation on the Administrator to inform about automated decision-making, including profiling referred to in Article 22(1) and (4) of the GDPR, and—at least in these cases—providing meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject. Therefore, the Administrator provides information regarding possible profiling in this section of the privacy policy.
The Administrator may use profiling within the Online Store for direct marketing purposes, but decisions made based on it do not concern concluding or refusing to conclude a Sales Agreement or the possibility of using Electronic Services in the Online Store. Profiling in the Online Store might result, for example, in offering a discount to a person, sending them a discount code, reminding them of unfinished purchases, sending product offers that might interest them, or offering better conditions compared to the standard offer of the Online Store. Despite profiling, the person makes independent decisions on whether to take advantage of the discount or better terms received and proceed with the purchase in the Online Store.
Profiling in the Online Store involves automated analysis or prediction of a person’s behavior on the Online Store’s site, such as adding a specific Product to the cart, browsing a specific Product page in the Online Store, or analyzing the purchase history. The prerequisite for such profiling is that the Administrator has the personal data of the person to subsequently send, for example, a discount code.
The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them.

6. RIGHTS OF THE DATA SUBJECT

Right of access, rectification, restriction, deletion, or transfer – the data subject has the right to request access to their personal data, its rectification, deletion (“right to be forgotten”), or restriction of processing from the Administrator, and has the right to object to processing, as well as the right to data portability. Detailed conditions for exercising the above rights are indicated in Articles 15-21 of the GDPR.
Right to withdraw consent at any time – if data is processed by the Administrator based on consent (under Article 6(1)(a) or Article 9(2)(a) of the GDPR), the data subject has the right to withdraw consent at any time without affecting the legality of processing based on consent before its withdrawal.
Right to lodge a complaint with a supervisory authority – the data subject has the right to file a complaint with a supervisory authority in the manner and mode specified in the provisions of the GDPR and Polish law, particularly 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 their particular situation – to the processing of personal data concerning them based on Article 6(1)(e) (public interest or tasks) or (f) (legitimate interests of the Administrator), including profiling based on these provisions. The Administrator shall no longer process the personal data in such cases unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or it is for the establishment, exercise, or defense of legal claims.
Right to object regarding direct marketing – if personal data is processed for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data concerning them for such marketing, including profiling to the extent that it is related to such direct marketing.
To exercise the rights mentioned in this privacy policy, contact the Administrator by sending a relevant message in writing or via email to the address specified at the beginning of the privacy policy or by using the contact form available on the Online Store’s website.

7. COOKIES AND ANALYTICS IN THE ONLINE STORE

Cookies are small pieces of text information in the form of text files sent by a server and saved on the side of the person visiting the Online Store’s website (e.g., on the hard drive of a computer, laptop, or smartphone memory card – depending on what device the visitor uses). Detailed information on cookies and their history can be found, among others, here: https://en.wikipedia.org/wiki/HTTP_cookie.
Cookies that may be sent by the Online Store’s website can be divided into different types according to the following criteria:

With regard to their provider: own (created by the Administrator’s Online Store website) and belonging to third parties/entities (other than the Administrator)

Due to their storage period on the device of the person visiting the Online Store website: session cookies (stored until logging out of the Online Store or closing the web browser) and permanent cookies (stored for a specified period of time, defined by the parameters of each file or until manually deleted)

Due to the purpose of their use: necessary (enabling the proper functioning of the Online Store website), functional/preferential (enabling the adjustment of the Online Store website to the preferences of the person visiting the website), analytical and performance (gathering information on how the Online Store website is used), marketing, advertising and social (collecting information about the person visiting the Online Store website in order to display advertisements to that person, personalize them, measure their effectiveness and conduct other marketing activities, including on websites separate from the Online Store website, such as social networking sites or other websites belonging to the same advertising networks as the Online Store)

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

The purposes of using Cookies in the Administrator’s Online Store	identifying Service Users as logged in to the Online Store and showing that they are logged in (essential Cookies)
	remembering Products added to the basket in order to place an Order (essential Cookies)
	remembering data from completed Order Forms, surveys or login details to the Online Store (necessary and/or functional/preference Cookies)
	adapting the content of the Online Store website to the individual preferences of the Service Recipient (e.g. regarding colors, font size, page layout) and optimizing the use of the Online Store websites (functional/preference Cookies)
	keeping anonymous statistics showing how the Online Store website is used (analytical and performance cookies)
	displaying and rendering advertisements, limiting the number of ad displays and ignoring advertisements that the Service Recipient does not want to see, measuring the effectiveness of advertisements, and personalising advertisements, i.e. examining the behavioural characteristics of people visiting the Online Store through anonymous analysis of their activities (e.g. repeated visits to specific pages, keywords, etc.) in order to create their profile and provide them with advertisements tailored to their expected interests, also when they visit other websites in the advertising network of Google Ireland Ltd. and Facebook, i.e. Meta Platforms Ireland Ltd. (marketing, advertising and social cookies)

4. You can check in the most popular web browsers which Cookies (including the period of operation of Cookies and their provider) are being sent at a given moment by the Online Store 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 media trackers” or “Content with trackers” box	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: (1) click the “Preferences” menu, (2) go to the “Privacy” tab, (3) click the “Manage website data” box	Regardless of the browser, using the tools available e.g. on the website: https://www.cookiemetrix.com/ or: https://www.cookie-checker.com/

5. By default, most web browsers available on the market accept the saving of Cookies. Everyone has the option to define the conditions for using Cookies through the settings of their web browser. This means that, for example, one can partially limit (e.g., temporarily) or completely disable the ability to save Cookies; however, this might affect some functionalities of the Online Store (for example, it may become impossible to proceed with the Order process through the Order Form due to the inability to remember Products in the cart during subsequent steps of placing the Order).

6. Web browser settings concerning Cookies are essential for the consent to use Cookies by our Online Store – as per the regulations, such consent can also be given through the web browser settings. Detailed information on changing Cookie settings and independently deleting them in the most popular web browsers is available in the help section of the web browser and on the following pages (just click the relevant link):

in Chrome browser

in Firefox browser

in Internet Explorer browser

in Opera browser

in Safari browser

in Microsoft Edge browser

7. The Administrator may use Google Analytics and Universal Analytics services provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) in the Online Store. These services help the Administrator conduct statistics and analyze traffic in the Online Store. The collected data is processed within these services to generate statistics useful for administering the Online Store and analyzing traffic. This data is aggregate in nature. By using the aforementioned services in the Online Store, the Administrator collects data such as the sources and mediums of acquiring visitors to the Online Store, their behavior on the Online Store, information about the devices and browsers they use to visit the site, IP and domain, geographic data, and demographic data (age, gender) and interests.

8. It is possible for individuals to easily block the sharing of information about their activity on the Online Store with Google Analytics—for instance, by installing a browser plugin provided by Google Ireland Ltd., available here: https://tools.google.com/dlpage/gaoptout?hl=pl.

9. Due to the potential use of advertising and analytical services provided by Google Ireland Ltd. in the Online Store, the Administrator highlights that complete information about the data processing principles for Online Store visitors (including information stored in Cookies) by Google Ireland Ltd. is available in Google’s privacy policy at: https://policies.google.com/technologies/partner-sites.

8. FINAL PROVISIONS

The Online Store may contain links to other websites. The Administrator encourages reviewing the privacy policies established on those sites after navigating to them. This privacy policy applies only to the Administrator’s Online Store.