PRIVACY POLICY

Lubatex Limited Liability Company with registered office in Lubawka

I. Data of the Personal Data Administrator

Please be informed that the administrator of your personal data is Lubatex Spółka z ograniczoną odpowiedzialnością, with its registered office at ul. Mickiewicza 17, 58-420 Lubawka, entered into the National Court Register under KRS number 0000231468 and using NIP number 6141554519, hereinafter referred to as the "Company". Contact with the Company regarding the protection of personal data is possible at e-mail address: This email address is being protected from spambots. You need JavaScript enabled to view it..

II. Data Protection Officer

The Company has a Data Protection Officer - currently Ms Patrycja Szreder who will be happy to help you with any issues relating to the protection of personal data, in particular to answer any questions you may have regarding the processing of your personal data. Contact with the Inspector is possible at the following e-mail address: This email address is being protected from spambots. You need JavaScript enabled to view it..

III. Objectives and grounds for processing personal data

To provide services, to conclude contracts for the sale of our products in accordance with the scope of our activities, the Company processes your personal data - for various purposes, but always in accordance with the law. Below you will find a detailed list of the purposes for which we process personal data, together with the legal basis.

For the purposes of service valuation and service performance, we process personal data such as:

name,
Email address,
sex,
order number,

The legal basis for such processing is Article 6(1)(b) of the b RODO, which allows the processing of personal data if they are necessary for the performance of a contract or taking steps to conclude a contract; if you choose to also provide your name, we consider that you have given your consent to the processing of your name as well - then the legal basis for such processing is Article 6(1)(a) RODO, which allows the processing of personal data on the basis of freely given consent;

In order to process a complaint, we process such personal data as:

name and surname,
email address,
order number,
increasingly residential address - if reimbursed,
Eventually the bank account number - if a refund is made,

- In order to contact you by telephone on matters related to the provision of the service, we process such personal data as:

phone number,
order number,
name and surname,

- insofar as you are interested in a form of telephone contact (we do not require a mandatory telephone number). The legal basis for such data processing is Article 6(1)(a) of the RODO, which allows us to process personal data on the basis of freely given consent;

- In order to issue invoices and comply with other obligations under tax law, such as keeping accounting records for 5 years, we process such personal data as:

Name and surname,
company name and details,
address of residence or registered office,
tax identification number,
order number,

The legal basis for such processing is Article 6(1)(c) of the RODO, which allows us to process personal data where such processing is necessary for the Data Controller to comply with its obligations under the law;

- In order to store unpaid enquiries, we process personal data such as:

name,
Email address,
order number,

- as it may happen that you decide to use the service some time after receiving the quote. The legal basis for such data processing is Article 6(1)(f) of the RODO, which allows the processing of personal data if in this way the Personal Data Controller pursues its legitimate interest (in this case, the Company's interest is to enable the conclusion of an agreement for a certain period of time without the need to repeat the valuation);

- In order to create records and registers related to the RODO, including for example a register of customers who have objected in accordance with the RODO, we process personal data such as:

name,
Email address,

because firstly, the provisions of the RODO impose certain documentation obligations on us to demonstrate compliance and accountability, and secondly, if you object to the processing of your personal data for marketing purposes, for example, we need to know to whom not to apply direct marketing because they do not wish it.

The legal basis for such processing is firstly, Article 6(1)(c) of the RODO, which allows the processing of personal data if such processing is necessary for the Data Controller to comply with its obligations under the law; secondly, Art. 6(1)(f) RODO, which allows the processing of personal data if, by doing so, the Personal Data Controller pursues its legitimate interest (in this case, the Company's interest is to have knowledge of individuals who are exercising their rights under RODO);

- In order to establish, pursue or defend against claims, we process personal data such as:

name and surname or, alternatively, company name,
residential address,
PESEL number or tax identification number,
Email address,
IP address,
order number,

The legal basis for such data processing is Article 6(1)(f) of the RODO, which allows the processing of personal data if, by doing so, the Personal Data Controller pursues its legitimate interest (in this case, the Company's interest is to have personal data to establish, assert or defend against claims, including those of customers and third parties);

- For archival and evidential purposes, we process personal data such as:

name,
Email address,
order number,

- for the purpose of securing information that may serve to prove facts of legal significance. The legal basis for such data processing is Article 6(1)(f) of the RODO, which allows the processing of personal data if, in this way, the Personal Data Controller pursues its legitimate interest (in this case, the Company's interest is to have personal data that will allow it to prove certain facts related to the provision of services, e.g. when some state authority requests it);

- In order to use cookies on the website, we process such textual information (cookies will be described in a separate section). The legal basis for such processing is Article 6(1)(a) of the RODO, which allows us to process personal data on the basis of freely given consent (when you first access the website, a request for consent to the use of cookies appears);

In order to administer the website, we process such personal data as:

IP address,
date and time of server,
web browser information,
operating system information,

- this data is saved automatically in so-called server logs, every time the website belonging to the Company is used. The administration of the website without the use of the server and without this automatic recording would not be possible. The legal basis for such data processing is Article 6(1)(f) of the RODO, which allows the processing of personal data if in this way the Personal Data Controller pursues its legitimate interest (in this case, the Company's interest is the administration of the website);

IV. Cookies

1. The Company on its website, like other entities, uses so-called cookies, which are short text information stored on your computer, phone, tablet or other device. They can be read by our system, as well as by systems belonging to other entities whose services we use (e.g. Facebook, Google).

2. Cookies perform a great many functions on the website, the most common being useful, which we will try to describe below (if the information is insufficient, please contact us):

providing security - cookies are used to authenticate users and prevent unauthorised use of the customer panel. They are therefore used to protect the user's personal data from unauthorised access,
impact on the processes and efficiency of website use - cookies are used to ensure that the website works smoothly and that you can use the functions available on it, which is made possible, among other things, by remembering your settings between visits to the website. Thanks to them it is possible to navigate the website and its sub-pages efficiently.
session status - cookies often store information on how visitors use a website, e.g. which sub-pages they view most often. They also make it possible to identify errors displayed on certain sub-pages. Cookies used to save the so-called "session state" therefore help to improve services and make browsing more comfortable,
Maintaining the session state - if a client logs in to his/her panel, cookies make it possible to maintain the session. This means that after navigating to another sub-page, you do not need to re-enter your login and password each time, which contributes to the comfort of using the website,
creation of statistics - cookies are used to analyse how users use the website (how many open the website, how long they stay on it, which content arouses most interest, etc.). This enables us to continually improve the website and adapt its operation to users' preferences. We use Google's tools, such as Google Analytics, to track activity and compile statistics; in addition to reporting website usage statistics, the Google Analytics pixel can also be used, together with some of the cookies described above, to help display more relevant content to you on Google services (e.g. Google search) and across the web,
use of social features - we have a so-called Facebook pixel on the website, which allows you to like our Facebook fanpage while using the website. However, for this to be possible, we must use the cookies provided by Facebook,

3. Importantly, many cookies are anonymous to us - without additional information, we are unable to identify your identity from them.

4. By default, your web browser allows the use of cookies on your device, so on your first visit we ask you to consent to the use of cookies. However, if you do not wish to use cookies when browsing the website, you can change the settings in your web browser - block the automatic handling of cookies completely or request notification each time a cookie is placed on your device. You can change your settings at any time.

5. While we respect the autonomy of all persons using the website, we feel obliged to warn you that disabling or restricting the use of cookies may cause quite serious difficulties in the use of the website, e.g. in the form of having to log on to each sub-page, longer loading times, restrictions on the use of functionalities, restrictions on liking the website on Facebook, etc.

V. Right to withdraw consent

1. Where the processing of personal data is based on consent, you may withdraw that consent at any time - at your discretion.

2. If you would like to withdraw your consent to the processing of your personal data, it is sufficient for you to do so:

send an email directly to the Company at This email address is being protected from spambots. You need JavaScript enabled to view it. or
send an email to the Data Protection Officer at This email address is being protected from spambots. You need JavaScript enabled to view it.

3. If the processing of your personal data was based on your consent, the revocation of your consent does not render the processing of your personal data unlawful until that point. In other words, we are entitled to process your personal data until you revoke your consent and revoking your consent does not affect the lawfulness of the previous processing.

VI.Requirement to provide personal data

1. The provision of any personal data is voluntary and at your discretion. However, in some cases, providing certain personal data is necessary in order to meet your expectations in using our services.

2. To request a service, it is necessary to provide your name, surname, address or registered office - without this we are unable to enter into the relevant contract.

VII. Automated decision-making and profiling

Please be advised that we do not perform automated decision-making, including based on profiling.

VIII. Recipients of personal data

1. Like most businesses, we rely on other entities to assist us in our operations, which sometimes involves the transfer of personal data. Therefore, if necessary, we pass on your personal data to the following recipients: lawyers cooperating with us who perform services, an accounting company, a hosting company, as well as an insurance company (should there be a need to repair a damage).

2. In addition to this, it may happen that, for example, on the basis of a relevant legal provision or a decision of a competent authority, we will also have to transfer your personal data to other entities, whether public or private. It is therefore extremely difficult for us to predict who may come forward with a request for personal data. However, for our part, we assure you that we analyse every request for personal data very carefully and very thoroughly in order not to inadvertently pass on information to an unauthorised person.

IX.Transfer of personal data to third countries

Please be informed that your personal data is not transferred outside the European Economic Area.

X. Period of processing of personal data

1. In accordance with current legislation, we do not process your personal data "indefinitely", but for the time that is necessary to achieve the stated purpose. After this period, your personal data will be irreversibly deleted or destroyed.

2. In situations where we do not need to perform operations on your personal data other than storing them (e.g. when we store the content of an order for the purpose of defending against claims), until permanent deletion or destruction we additionally secure them - through encryption.

3. Regarding the individual periods of personal data processing, we kindly inform you that we process personal data for the period:

contract duration - with regard to personal data processed for the purpose of concluding and performing a contract;
3 years or 10 years + 1 year - with regard to personal data processed for the purpose of establishing, asserting or defending claims (the length of the period depends on whether both parties are entrepreneurs or not);
6 months - with regard to personal data which were collected when pricing a service and at the same time the contract was not concluded immediately;
5 years - with regard to personal data connected with fulfilment of tax law obligations;
until withdrawal of consent or achievement of the purpose of processing, but for no longer than 5 years - with regard to personal data processed on the basis of consent;
until an effective objection is lodged or the purpose of processing is achieved, however for no longer than 5 years - with regard to personal data processed on the basis of a legitimate interest of the Personal Data Administrator or for marketing purposes;
until it becomes obsolete or loses its usefulness, however for no longer than 3 years - with regard to personal data processed mainly for analytical purposes, the use of cookies and website administration;

4. We count periods in years from the end of the year in which we began processing personal data in order to streamline the process of erasure or destruction of personal data. Counting the period separately for each event would involve significant organisational and technical difficulties, as well as a significant financial outlay, so establishing a single date for the erasure or destruction of personal data allows us to manage this process more efficiently. Of course, if you exercise your right to be forgotten, such situations are dealt with on a case-by-case basis

5.The extra year associated with the processing of personal data collected for the performance of a contract is dictated by the fact that hypothetically you may make a claim moments before the expiry of the limitation period, the request may be served with a material delay or you may misstate the limitation period for your claim

XI. Entitlements of data subjects

1.We kindly inform you that you have the right to:

access to your personal data;
correction of personal data;
deletion of personal data;
restrictions on the processing of personal data;
objection to
transfer of personal data;
the processing of personal data;

2. We respect your rights under data protection legislation and endeavour to facilitate the exercise of these rights to the greatest extent possible.

3. We point out that the rights listed are not absolute and therefore we may lawfully refuse to grant you these rights in certain situations. However, if we refuse to comply with a request, it is only after careful consideration and only if it is necessary to refuse the request.

4. Regarding your right to object, we explain that you have the right to object at any time to the processing of personal data on the basis of the legitimate interests of the Personal Data Controller (these are listed in section III) in relation to your particular situation. However, you must bear in mind that, according to the legislation, we may refuse to take your objection into account if we show that:

there are legitimate grounds for processing which override your interests, rights and freedoms or;
there are grounds for the establishment, assertion or defence of claims;

5.In addition, you may object at any time to the processing of your personal data for marketing purposes. In such circumstances, upon receipt of your objection, we will cease processing for that purpose.

6.You can exercise your rights by:

sending an email directly to the Company at This email address is being protected from spambots. You need JavaScript enabled to view it. or
sending an email to the Data Protection Officer at This email address is being protected from spambots. You need JavaScript enabled to view it.

XII.Right to lodge a complaint

If you believe that your personal data is being processed contrary to applicable law, you may lodge a complaint with the President of the Office for Personal Data Protection.

XIII.Final provisions

1. To the extent not covered by this Privacy Policy, the provisions of data protection law shall apply.

2. You will be notified by email of any changes made to this Privacy Policy.

3.This Privacy Policy is effective as of May 25, 2018.