PRIVACY POLICY
of www.flhf.com.pl
I. Who is the controller of your personal data?
The controller of your personal data (hereinafter referred to as the “Controller”), responsible for safety of your personal data is:
FLHF S.A. with its registered seat in Wrocław, ul. Słonimskiego 1A, 50–304 Wrocław, entered into the register of entrepreneurs of the National Court Register (KRS) maintained by District Court for Wrocław-Fabryczna in Wrocław 6th Commercial Division for the National Court Register under KRS number: 0000728264, NIP (tax identification number): 8982242989, e-mail: info@flhf.com
II. How do we protect your personal data?
The Controller has implemented internal procedures pursuant to requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free transfer thereof and repealing Directive 95/46 / EC (General Data Protection Regulation, hereinafter referred to as “GDPR”). The above-mentioned procedures provide effective protection of your personal data.
- Controller takes appropriate measures to protect your personal data.
- Controller respects all personal data security rules and provides the highest possible level of protection of your personal data.
- Controller undertakes any activities required by law, to limit the amount of personal data obtained from you.
- Controller erases your personal data, if they are no longer necessary for the purpose of their processing and in accordance with applicable law.
III. Which and for what purpose do we process your personal data?
A. Registration of the account and acquiring goods through FLHF B2B platform
In order to register account at FLHF B2B platform, we ask you to provide the following personal data: company name, tax identification number, first and last name, e-mail address, telephone number, business address including: street, house number, city, zip code and country. These data are necessary to register account at FLHF B2B platform and to purchase goods offered by the Controller on the platform. Additionally, we ask you to attach your business’ registration certificates in electronic version from National Court Register or Central Registry and Information about Business Activities. In case of logging in the platform after completed registration, we only ask you to provide login and password.
B. Contact form
In order to enable you to use contact form, we process your following personal data: first and last name, e-mail address and optionally also company’s name and telephone number, i.e. necessary data to identify contact’s form user and to answer on your enquiry.
C. Telephone contact
In order to enable you telephone contact at numbers indicated at www.flhf.com.pl, we process only your telephone number.
D. Recruitment
In case to apply for current vacancies, we ask you to send your CV including information that each candidate should deliver on a basis of art. 22 (1) of Polish Labour Code i.e. name (names) and surname, date of birth, contact data, and in case that it is necessary to perform certain kind of job or to perform a job on certain position – education, professional qualifications and employment history.
E. Processing of personal data of customers of the www.amazon.pl online store who purchase goods from the Controller in www.amazon.pl online store
The Controller may process personal data of customers of the www.amazon.pl online store operated by Amazon EU SARL with its registered office in Luxembourg, represented in Poland by its registered branch – AMAZON EU SARL Sp. z o.o., ul. Jana Pawła II 29, 00-867 Warsaw, KRS no.: 0000827545, tax identification number (NIP): 1080023913, who purchase goods offered for sale by the Controller in www.amazon.pl online store. For this purpose, the Controller may process personal data from the API form provided by Amazon EU SARL, which include:
– Customer’s first and last name;
– the delivery address of the ordered goods (street, house and flat number, postal code and city);
– specification of the ordered goods;
– details of payment;
– details of invoices or receipts issued to the customer;
– customer’s order history;
– country of delivery of the goods;
– waybill number.
IV. Legal bases for the processing of your personal data
Legal basis for the processing of your personal data in the scope indicated in point III sec. A of this Privacy Policy is point (b) of Article 6 (1) of GDPR i.e. necessity of processing for the performance of the agreement of providing account at FLHF B2B platform. In case of conclusion of sale agreement through FLHF B2B platform, the legal basis for processing your personal data is point b) of Article 6 (1) of GDPR i.e., necessity of the processing for the performance of the agreement by the Controller.
In scope indicated in point III sec. B and C of this Privacy Policy is point (a) of Article 6 (1) of GDPR i.e. your consent given to the processing of personal data in order to make an enquiry through contact form or to obtain telephone contact.
Legal basis for the processing of your personal data in the scope indicated in point III sec. D of this Privacy Policy is point (a) of Article 6 (1) of GDPR i.e. your consent given to the processing of personal data in order to send job application.
The legal basis for the processing of your personal data to the extent indicated in point III sec. E of this Privacy Policy is point (f) of Article 6(1) of GDPR, i.e. the Controller’s legitimate interest in collecting and storing information about customers purchasing the Controller’s goods through www.amazon.pl online store in order to take measures aimed at increasing sales and adapting the offer and assortment to customers’ preferences.
V. Which of your personal data are collected automatically after entering website www.flhf.com.pl?
A. Server
The Controller’s IT system automatically collects in its logs the details of the device used while connecting to the website www.flhf.com.pl. These data relate to IP, addresses of the source sites where the files were downloaded from, the output address and are used only for diagnostic purposes.
These data are never combined with the data referred to in the part III hereof and are only material for statistical analysis and system error correction mechanisms.
B. Cookies
The website www.flhf.com.pl uses the technology of cookies, which are text files placed on the devices interacting with our website for technical purposes of the connection session.
By using cookies files, the website collects anonymous (cannot be used to identify individual users) information about the user used to:
a) create statistics, which help us understand the way you use the website, which enables us to improve its structure and content;
b) maintain your session at www.flhf.com.pl and its subpages.
Cookies are saved on your device (smartphone, PC, tablet etc.) and enable you access to all functions of the website.
The Controller is the only entity which has access to cookies files saved on your device.
The Controller provides that cookies files do not cause any changes in your final device.
You may at any time remove cookies files from your device or block the possibility to use them in the future by configurating your browser. Guidelines of how to block or remove cookies files from your device can be found at the following subpages, depending on the browser that you use:
• Edge
• Internet Explorer
• Chrome
• Safari
• Firefox
• Opera
Mobile devices:
• Android
• Safari (iOS)
• Windows Phone
Non-deactivation of cookies files in browser settings is equivalent with your consent to use cookies by the website. However, the Controller warns that deactivation of cookies files necessary for authentication, security and keeping user’s preferences in your browser may harm some of the website’s functions.
Website uses two types of cookies: session cookies and persistent cookies. Session cookies are temporary files which are stored in your device until you are browsing website. Persistent cookies are stored in your device within the period fixed in cookies files’ parameters or until their manual removal from your device.
C. Google Analytics (cookies)
Google Analytics uses the technology of cookies, which are text files placed on the device connecting with our website to enable the Controller to analyse the website traffic and the manner in which visitors use the website.
Google collects data obtained from the placement of cookies on the devices interacting with our website on its servers and uses this information to create reports and provide other services related to the traffic and use of the Internet.
Google may also transfer this information to third parties if it is required to do so by law or in case when these third parties process such information on behalf of Google.
You can acknowledge and edit your preferences collected by Google advertising network resulted from cookies files by using the tool available at: https://www.google.com/ads/preferences/.
These data are never combined with the data referred to in the part III hereof and are only material for statistical analysis and system error correction mechanisms.
If you do not agree to the placement of cookies on your device, you can block their placement by configuring your web browser. The instruction on how to block the cookies can be found in the help files of your web browser. Unfortunately, if you block cookies from Google, we cannot guarantee the correct operation of the website www.flhf.com.pl.
If you agree to place cookies on your device, but wish to delete them after completing your visit, you can do it without risk. The instruction on how to delete the cookies can be found in the help files of your web browser.
D. Google AdWords (cookies)
Google AdWords uses the technology of cookies, which are text files placed on your device, to enable the Controller to analyse the correctness and efficiency of advertising campaign based on AdWords network.
Google collects data obtained from the placement of cookies on the devices interacting with our website on its servers and uses this information to create reports and provide other services related to the traffic and use of the Internet.
Google may also transfer this information to third parties if it is required to do so by law or in case when these third parties process such information on behalf of Google.
These data are never combined with the data referred to in Part III and are only material for statistical analysis and system error correction mechanisms.
If you do not agree to the placement of cookies on your device, you can block their placement by configuring your web browser. The instruction on how to block the cookies can be found in the help files of your web browser. Unfortunately, if you block cookies from Google AdWords, we cannot guarantee the correct operation of the website www.flhf.com.pl. If you agree to place cookies on your device, but wish to delete them after completing your visit, you can do it without risk. The instruction on how to delete the cookies can be found in the help files of your web browser.
VI. Recipients of your personal data
Your personal data indicated in point III of this Privacy policy will not be disclosed to any third parties.
Only in particular circumstances, in which generally applicable law requires us to disclose your personal data to entitled state authorities, we will disclose such data.
The Controller ensures that in case of necessity of entrusting third entity with processing activities, the Controller will entrust the processing of your personal data only to the entity that guarantees high level of protection of personal data, with whom the Controller will conclude personal data processing agreements.
The Controller also does not intend to transfer your personal data to a third country or international organization. However, in case of such necessity, your personal data will be transferred only where the European Commission has decided that the third country, a territory or one or more specified sectors within that third country, or the international organization in question ensures an adequate level of protection, according to Article 45 of GDPR.
VII. Period of storage of your personal data
Your personal data which processing is based on your consent will be stored until the end of the period for the consent was given, i.e.:
– until the removal of your account from FLHF B2B platform;
– until the end of correspondence following your query made through contact form;
– until the end of the telephone call.
Your personal data which processing is based on point (b) of Article 6 (1) of GDPR i.e. on the basis of agreement for sale of goods offered by the Controller at FLHF B2B platform, will be stored until the final performance of the agreement. However, if processing of such personal data is necessary for the establishment, exercise or defense of legal claims resulting from the agreement, your personal data may be processed by the Controller until the expiry of limitation period of such claims, which generally is 6 six years from the end of the calendar year in which the agreement has been concluded or until final settlement of court or administrative proceedings.
Your personal data processed for the purposes of recruitment will be processed only for the period of its conduct, unless you have given your explicit consent to its processing also for the purposes of further recruitments.
Personal data of the customers of the www.amazon.pl online store will be stored for the period when the Administrator offers goods for sale in this online store, unless you have previously lodged an effective objection to the processing of your personal data for this purpose.
VIII. Exercising of your rights in accordance with processing your personal data
A. Right of access to personal data
You have the right to obtain confirmation from us whether we process your personal data, and if this is the case, you have the right to:
a) access your personal data;
b) obtain information about the purposes of processing, categories of personal data being processed, the recipients or categories of recipients of this data, the planned period of storage of your data or criteria for determining this period, about your rights under the GDPR and the right to lodge a complaint to the supervisory authority, the source of these data, on automated decision-making, including profiling and safeguards applied while transferring these data outside the European Union;
c) obtain the copy of your personal data.
Applicable law: Article 15 of GDPR
B. Right to rectification of personal data
You have the right to rectify and to complete your personal data with additional information. You can exercise this right by submitting a request to rectify the data (if data are inaccurate) and to complete them with additional information (if data are incomplete).
Applicable law: Article 16 of GDPR
C. Right to erasure of personal data („right to be forgotten”)
You have the right to request removal of all or some of your personal data. You have a right to request removal of your personal data from our system if:
a) you have withdrawn your consent to process your personal data which have been processed based on your consent;
b) your personal data are no longer necessary for the purpose which they have been collected for or processed;
c) you have objected to use your personal data for marketing purposes;
d) your data are being processed unlawfully.
e) your data have to be erased for compliance with applicable EU or national law to which the Controller is subject;
f) your data have been collected due to performing information society service.
Despite your request to erase your personal data, raised as the opposition or withdrawal of consent to data processing, RGB Company may retain certain your personal data to the extent necessary to establish, assert or defend claims or if it is necessary for compliance with applicable EU or national law to which the Controller is subject.
Applicable law: Article 17 of GDPR
D. Right to restriction of processing
You have the right to request a restriction of processing your personal data. If you submit suc request, we will prevent you from using certain functionalities or services which need the data whose processing you want to restrict until we process your data restriction request. You have the right to request restrictions on the use of your personal data in the following cases:
a) your personal information stored in our system is incorrect;
b) your data are processed in unlawful way;
c) your personal data are no longer necessary for the purpose which they have been collected for or processed but are still necessary to establish, assert or defend claims;
d) you have objected to use your personal data. In this case, the restriction is made for the time needed to consider whether, due to your special situation, the protection of your interests, rights and freedoms outweighs the interests that we pursue by processing your personal data.
Applicable law: Article 18 of GDPR
E. Right to object to processing
You have the right to object to the processing of your personal data at any time in case when point (f) of Article 6 (1) of GDPR, i.e. legitimate interests pursued by the controller are the only basis for processing your personal dat. If your objection proves to be well founded and we have no other legal basis to process your personal data, we will erase the data for processing you objected.
Applicable law: Article 21 of GDPR
F. Right to withdraw consent
You have right to withdraw your consent if it is the legal basis for processing. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. The withdrawal of consent does not have any negative consequences for you. However, it may prevent you from using store’s services or some functionalities that we can legally provide only with your consent.
Applicable law: Article 7(3) of GDPR
G. Right to lodge a complaint with a supervisory authority
If you consider that your personal data rights have been infringed, you have a right to lodge a complaint to supervisory authority – President of the Personal Data Protection Office.
Applicable law: Article 77 of GDPR
If, by exercising your afore-mentioned rights, you submit a request to us, we will comply with this request or refuse to comply with it without delay, but no later than one month after receipt. However, if – due to the complexity of the request or the number of requests – we will not be able to meet this deadline, we will process your request within next two months, informing you in advance about postponing the deadline.
You can also send us complaints, requests and motions related to processing your personal data and your rights.
IX. Automated individual decision-making and profiling
We ensure that processing of your personal data will not be based on automated processing, including profiling.
X. Requirement of the provision of your personal data
Provision of your personal data necessary to make a query through contact form and to access telephone contact is completely voluntary, but however it is a requirement to contact us through those channels of communication. Your failure to provide required personal data will prevent communication through those channels.
Provision of your personal data required to register account in FLHF B2B is the necessary condition to create your account. Your failure to provide required personal data will prevent the possibility of account registration in FLHF B2B platform and purchasing goods offered by the Controller on that platform.
XI. Amendments of Privacy policy
The Controller reserves the right to amend this Privacy policy, if it is required by applicable law, operational conditions of the website or in case when the intended modification will introduce a higher standard than the minimum required by law. You will be informed about all amendment in Privacy policy in advance.
XII. Contact
If you have any questions or doubts about our Privacy policy and your personal data protection or in case you wish your personal details to be updated or removed but you have no possibility or simply prefer not to do it yourself, do not hesitate to contact us at: info@flhf.com.