Privacy Policy
We care about your privacy. Therefore, we collect and process your data only if it is necessary, and only such data that you provide to us.
If you have any questions or concerns about the information contained in this Privacy Policy or other issues related to the processing of personal data by the Administrator, or if you want to exercise the rights referred to in this Privacy Policy, please contact us at: hello@slowgrow.pl, or by letter to: Online Store slow grow, ul. Magazynowa 13b/64, 02-652 Warszawa, Poland.
§ 1 PERSONAL DATA PROTECTION
This Privacy Policy contains the principles of privacy protection (i.e. the rules of collecting, use, processing and protection) of personal data of the Store users available at www.slowgrow.pl (hereinafter referred to as the "Store" or “Online Store”), as well as the scope of use of the so-called Cookies by the Store.
We process your personal data in accordance with applicable laws, in particular 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”).
Who is the controller of your data?
The controller of your personal data provided to the Seller or during the use of social media platforms belonging to the Store, in particular the data you provide to us in the process of placing an order, user registration or when subscribing to our Newsletter is:
OFFLINE KIDS sp. z o.o. with seat in Warszawa, Poland
registered address: Sienna str. 64, 00-825 Warszawa, Poland
entered into the National Court Register under the number KRS: 0000876471
Tax ID no. (NIP): 5213916346
Share capital: PLN 5,000
contact e-mail address: hello@slowgrow.pl
(hereinafter referred to as the: "Seller" or "Controller")
What data does the Store collect and can I refuse to provide data?
We collect and process only such personal data, i.e. the data based on which the user can be identified, which the user provides himself e.g. in the process of placing an order.
Browsing the website of our Store does not require registration or providing any personal data.
Providing personal data is voluntary. However, refusal to provide personal data may make it difficult or completely impossible to process an order or to conduct some of the services offered by the Controller. For example, failure to provide name, surname and an e-mail address will make it impossible to place an order (and thus to conclude a contract), while in the case of the Newsletter service, failure to provide an e-mail will prevent its sending.
What are your rights in connection with the processing of personal data by the Controller?
As the data subject, i.e. a user whose personal data we process, you have the right to:
- access your personal data;
- request rectification of your personal data;
- erasure of your personal data (e.g. if there are no grounds for processing) or right to restriction of their processing;
- object to the processing of your personal data;
- data portability, pursuant to Article 20 of GDPR;
- withdrawal of consent to the processing of your data, if the consent was the basis for their processing by the Controller, and
- o lodge a complaint with a supervisory authority.
Any requests in this regard may be submitted directly to the Controller, in any form that will be convenient for you, e.g. by an e-mail, contact form, post. The Controller’s contact details are provided at the beginning of this Policy. Please remember that these rights are not absolute and do not apply to all processing of your personal data. For more information and to learn the limitations on your rights, please check the details of Articles 16 - 21 of GDPR.
Each time you make the above requests, we will reply to them within one month, adequately justifying further actions resulting from legal obligations.
Notwithstanding the above, you always have the right to lodge a complaint to the supervisory authority, which is the President of the Office for Personal Data Protection (in Poland). In such a case, however, we encourage you to contact the Controller in advance to clarify your doubts.
You can also always turn to the Controller with a request to provide information on what data the Controller holds about you and for what purposes it processes the data (right of access to personal data).
Notwithstanding the above, please find below more detailed information on rules of data processing by the Controller, as well as on what rights you have in relation to your personal data and for what purposes we process your personal data.
For what purposes, on what legal basis and for how long we process your personal data?
We do not process your personal data by automated means (no profiling takes place).
We process your personal data only for the following purposes and based on the indicated legal grounds:
- Fulfilment of orders placed in our Store
To place an order in the Store, we will ask you to provide us with the data necessary to process the order, such as your name, billing and shipping address (for physical products), an e-mail address (where we will send the order confirmation), as well as a phone number (voluntarily) to facilitate delivery by the selected carrier.
For orders placed as part of your business activity, we will also ask you to provide your full company name, registered address, and tax identification number.
Providing this data is voluntary, but necessary to place the order or for proper delivery in case of certain delivery methods.
The data provided in connection with your order will therefore be processed for following purposes: processing your order (Article 6 para 1 letter b) of GDPR, issuing an invoice (Article 6 para 1 letter c) of GDPR), including the invoice in our accounting records (Article 6 para 1 letter c) of GDPR), for the purpose of dealing with any product complaints, including to be able to prove certain facts by the Controller if this proves necessary (evidential purposes) (Article 6 para 1 letters b) and c) of GDPR). We may also process your data for archival and statistical purposes (Article 6 para 1 letter f) of GDPR).
Order data will be processed for the time necessary to process the order and thereafter until the expiry of the limitation period for claims under the concluded contract. In addition, after the expiry of this period, the data may still be processed for statistical purposes. Please also note, that as a Seller, the Controller is obliged to store settlement documents (invoices) with your personal data for a period of 5 years from the end of the tax year in which the tax obligation arose.
In the case of order data, you do not have the opportunity to rectify this data after the order has been processed. You also cannot object to the processing of your data or request to erasure your data until the expiry of the limitation period for contractual claims. Likewise, you may not object to data processing and request erasure of data contained in invoices or other billing documents that require the name of the buyer. However, after the expiry of the limitation period for claims under the concluded contract, you may object to the processing of your data for statistical purposes, as well as request deletion of your data from the Controller's database.
In relation to your order data, you also have the right to data portability referred to in Article 20 of GDPR. It consists in the fact that you have the right to receive from the Controller an extract of the personal data processed by the Controller, in a structured form in accordance with the requirements of GDPR.
- Newsletter
If you would like to receive our Newsletter and keep up to date with news, great offers, interesting publications on the blog, or just know what is going on with us, you can subscribe to our Newsletter. Subscribing to the Newsletter takes place via the Newsletter subscription form and requires providing your e-mail address and name. Providing the data is voluntary, but necessary to subscribe to the Newsletter.
Data provided during subscription to the Newsletter will be used only for the purposes of the Newsletter service to inform you about products and novelties included in our Store offer. The legal basis for processing you personal data in this case is the implementation of a legitimate interest pursued by the Controller, which is direct marketing (Art. 6 para 1 letter f) of GDPR).
The data will be processed for the duration of the Newsletter service offered by the Controller unless you unsubscribe from the Newsletter earlier or object to the processing of your personal data in this scope. Please note that unsubscribing from the Newsletter does not result in complete removal of your data from the Controller's database. Although we will no longer send you the Newsletter, your data will still be stored in the mailing system in order to defend against possible claims related to the sending of the Newsletter (art. 6 para 1 letter c) and f) of GDPR).
You can rectify your data stored in the Newsletter database at any time. You also have the right to data portability as referred to in Article 20 of GDPR.
- Contact with the Store
By initiating contact with us via email or via social media platforms, you provide us - as the sender of the message - with your name and, depending on the means of communication, your email address or profile name. The provision of this data is voluntary, but necessary to establish contact.
Your data is processed in this case for the purpose of communicating with you and responding to your enquiry, and the basis for processing is Article 6 para 1 letter a) of GDPR, i.e. your consent resulting from the initiation of contact. In the case of enquiries about products from the Store before you place an order, the legal basis is also Article 6 para 1) letter b) of GDPR (processing is necessary to take steps prior to entering into a contract). The legal basis for post-contact processing is the Controller's legitimate interest of archiving the correspondence for the purpose of showing its course in the future (Article 6 para 1 letter f) of GDPR).
The content of correspondence conducted in this way may be archived. We cannot explicitly state when it will be deleted. However, you always have the right to request the history of the correspondence (if it has been archived) as well as to request its deletion, unless its archiving would be justified by an overriding interest of the Controller, e.g. the defense against potential claims on your part.
- Comments on Facebook, Instagram
Whenever you leave a comment on social media platforms managed by the Store, you naturally leave a trace of our profile in the form of your profile name on the respective social media platform. The basis for data processing in this case is Article 6 para 1 letter a) of GDPR, i.e. your consent to interact on social media platforms.
In this case, your data will be processed for the duration of the Controller's business, including keeping accounts on social media platform by the Controller, unless you ask for the removal of your comment, which will result in your data being removed from the database.
You also have the right to request the deletion of your data from the social media platforms. You can also exercise these rights within your Facebook or Instagram user account directly against the owner of these social media platforms, who in this case is joint controller of your personal data.
You also have the right to data portability referred to in Article 20 of GDPR.
- Maintaining a registered user account in the Store
Regardless of whether you place an order in our Store or not, you can create an account of a registered user of the Store (free service provided by the Seller). Having an account in our Store is free and voluntary. On your account you will have access to e.g. order history, order fulfillment status. It will also allow you to manage your data and consent to receive the Newsletter. More information on the functionality of the user account can be found in our Terms and Conditions.
In order to create a registered user account, you need to provide your first name, surname, e-mail address.
The data provided in connection with user registration will be processed for the purpose of performance of the contract on provision of electronic services by the Seller - establishment, maintenance, and management of a registered user account (Article 6 para 1 letter b) of GDPR), handling possible complaints regarding account (Article 6 para 1 letters b) and c) of GDPR), as well as possibly for archival and statistical purposes (Article 6 para 1 letter f) of GDPR).
Your data will be processed for as long as the Controller is in business, unless you delete your account earlier. In the latter case, however, your data will still be processed until the expiry of the limitation period for claims under the concluded contract for the provision of electronic services.
In the case of and within the scope of the registered user account service, you always have the opportunity to request rectification or completion of your data, and this for as long as you hold a registered user account in our Store. However, you may not object to data processing or request deletion of data until the expiry of the limitation period for claims under the contract. After the expiry of the limitation period for claims under the registered user account service, your data will be deleted from the Controller's database.
Also, in this case, you have the right to data portability as referred to in Article 20 of GDPR.
To whom may we disclose your personal data (data recipients)?
Your personal data may be disclosed to the Controller's subcontractors, but only if this proves necessary for the performance of the contract with you, or another purpose of the processing.
Thus, your personal data may be provided to the following categories of data recipients: IT service providers - Internet Store software and operator, hosting service providers, e-mail service providers, courier service providers (including intermediary platforms such as apaczka.pl or furgonetka.pl), postal service providers, accountants, marketing service providers, Newsletter service providers, and companies providing electronic payment solutions (e.g. quick online payments, Paypal). The category of data recipients may also include companies supporting our Store in handling shipments (storage, packaging, handling returns and complaints) and invoicing.
These entities guarantee appropriate measures to protect the confidentiality and security of personal data as required by law. Moreover, they may not use the personal data provided to them for purposes other than those for which they were entrusted to them by the Controller.
Due to fact that we use the services of Google (Google Analytics, Google Tag Manager), Facebook (Facebook Pixel), MailChimp which handles the sending of the Newsletter, your data may be transferred outside the European Union ("EU") due to its storage on servers located outside the EU and used by the aforementioned entities (and therefore outside the scope of GDPR). However, these entities guarantee an adequate level of protection of personal data as required by European Union law. These entities use compliance mechanisms such as standard contractual clauses. Detailed information is available in the content of the privacy policy of each of these service providers, available on their websites:
Is your data safe?
We take all necessary steps and measures to ensure the security of your personal data and to prevent access by unauthorized persons.
In particular, only authorized persons who are obliged to keep your personal data confidential will have access to it.
Currently on the Store website we use redirections to our social media profiles on Facebook https://www.facebook.com/Slow-grow-108928700848890 and on Instagram https://www.instagram.com/slow.grow_/. In the event that links to websites other than those indicated above appear on the Store's website, we would like to clarify that the Controller is not responsible for the content provided by these websites or, if applicable, the manner in which these websites collect and process the users' data. The user is obliged to familiarize himself with the privacy policy or the regulations of these websites.
§ 2 COOKIE POLICY
On our website we use the mechanism of so-called "Cookies".
What are Cookies?
„Cookies” are small text files that record your online activity. When you browse and use our Store, Cookies are stored on your device, e.g. computer, tablet, laptop, smartphone.
We divide Cookies into temporary (session) and permanent ones. Session Cookies are deleted when the internet browser session ends (when you close it). Persistent Cookies, on the other hand, are stored on your terminal device and enable recognition of your browser the next time you visit the website.
However, we do not automatically collect any information other than that relating to your visit: your IP address, domain name, browser type, etc. This data is processed only for the purposes of administering the Store website, ensuring efficient operation of the Store, and is not associated with the personal data of individual users.
Cookies are not used to identify users, and on their basis, we are not able to determine the identity of the user visiting the Store. Cookies also do not change the configuration of your device, nor do they serve to install or uninstall any program or application on your device. Cookies also do not interfere with the integrity of your system or your data.
What specifically are Cookies used for?
Cookies allow us, for example, to better customize the content of a website so that you can use it more comfortably. Cookies facilitate navigation on our website and allow us to personalize the interface of the site you are viewing - they remember the selected resolution, content layout or, for example, the selected language.
Cookies make it possible to maintain the user session after logging into the Store. Thanks to this, as a registered user you will not have to re-enter your username and password on each subpage of the Store.
Cookies also allow us to understand how our customers use our website, from where they were redirected to the Store website, the number of visits, the time of their visit (which in turn enables us to improve the structure, content and offer of the Store).
We may also use advertising Cookies which enable us to provide users with advertising content more suited to their interests.
Your consent to Cookies
The temporary storage of log files and Cookies facilitates the use of our website.
For this reason, users are asked to agree to the use of Cookies by our Store. Granting such consent is optional and does not affect the possibility of using the Store website. In some cases, however, without such consent, the possibility of using the Store website may be limited to a certain extent.
Moreover, in many cases the software used to browse the website (i.e. the Internet browser you use) allows the storage of Cookies on your terminal device by default. However, you have the possibility to determine the conditions of use of Cookies through the settings of your web browser, in particular you can disable the Cookies mechanism yourself.
Please note, however, that disabling Cookies may cause difficulties or prevent proper and uninterrupted use of our Online Store.
Third party Cookies
Our website also uses certain functionalities provided by third parties, and this in turn involves the use of Cookies from those entities. We use the following solutions within our Store:
Facebooka Pixel – we use the Facebook Pixel to manage Facebook ads and conduct remarketing activities. This is our legitimate interest - direct marketing. The Facebook Pixel is a small piece of code placed on our website. It helps to measure the effectiveness of ads, shows what actions Store users take and helps to reach a specific group of people (Facebook Ads, Facebook Insights). However, the information collected within the Facebook Pixel is anonymous, i.e. it does not allow to identify you. Please note, however, that Facebook may combine this information with other information about you collected as part of your use of Facebook and use it for its own purposes, including marketing.
However, this is no longer under our control. For more information, please refer directly to Facebook's privacy policy: https://www.facebook.com/privacy/explanation. Furthermore, you can manage your privacy settings from your Facebook account.
You can also decide whether you agree to the use of the Facebook Pixel as part of the Cookie settings accessible from the Store website.
Google Analytics – we use Google Analytics. This solution is used to analyze the web page statistics of our Store. Google Analytics uses its own Cookies to analyze actions and behaviors of the Store's users. The Cookies are placed on the user's computer and thanks to them we can see e.g. which website the user came from to the Store website. This tool is provided by Google LLC. Actions taken with the use of Google Analytics code are based on the Controller's legitimate interest in the creation and use of statistics. Thanks to Google Analytics, we can improve our services and optimize the pages of the Store even better. As part of the use of the Google Analytics tool, however, we do not process any user data, so we cannot identify you as a user.
If you are interested in the details related to the data processing within Google Analytics, we encourage you to read the explanations prepared by Google: https://support.google.com/analytics/answer/6004245?hl=en
You can decide whether or not you consent to the use of Google Analytics as part of the Cookie settings available on the Store website.
Google Tag Manager – we use the Google Tag Manager tool provided by Google LLC. This tool allows us to analyze the advertising campaigns we run and how you use our sites. This is our legitimate interest - direct marketing and the creation of statistics and analysis.
When visiting our website, a Google Cookie is automatically stored on your device, which, with the help of a pseudonymous identifier (ID) and based on the pages you visited, allows us to display to you interest-based advertising, control the effectiveness of these ads and to undertake other activities related to the analysis of your behavior on the website.
You can deactivate Cookies related to the use of this tool within the settings of your Google account: https://adssettings.google.com. Furthermore, you can disable the use of Cookies for remarketing purposes in your browser settings. .
Social Media Referral Plugins – we use social media referral plugins on the Store website: Facebook, Instagram.
By clicking on the "Like" or "Share" button in relation to, for example, a post, product or photo, information about this activity will be sent directly to the server of the relevant social media provider and stored there. The purpose and scope of data collection, the principles of data processing by these service providers (owners of social media platforms), your rights in this regard as well as the possibility of changing the settings to ensure the protection of your privacy are described in the privacy policies of the respective service providers. The Controller has no influence on the data processed by these entities.
In addition, by clicking "Like" or "Share", your activity will also be visible to the persons in your contact list of the respective social platform.
If you do not want social media platforms to associate the data collected during your visit to the Store's website with your profile on a given social media page, simply log out of before visiting the Store's website.
The Controller reserves the right to introduce changes to this Privacy Policy. The changes may be caused in particular by the development of Internet technology, changes in the generally applicable law or the development of the Store website by e.g. use of new tools or technologies by the Controller.
This Privacy Policy shall enter into force on 18.10.2021 r.