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Privacy policy

§ 1. General provisions

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This Privacy Policy sets out the principles for ensuring the privacy and processing of the personal data of persons using the website, and the services offered through the website, available on the internet at apilus.pl (the “Website”). The Website is run by ELEKTROEPILACJA.PL SP. Z O.O., a limited liability company with its registered office in Warsaw at ul. Grzybowska 87, 00-844 Warszawa, entered in the Register of Entrepreneurs of the National Court Register (Krajowy Rejestr Sądowy) kept by the District Court for the Capital City of Warsaw in Warsaw, XIII Commercial Division of the National Court Register, under KRS number 0001064299, REGON 526700960, NIP 5273080710, which is the controller of the personal data (the “Controller”) collected, processed and used in connection with the use of the Website by its users (the “Users”, and each a “User”). You can contact the Controller by email at: contact@elektroepilacja.pl or by post at: ELEKTROEPILACJA.PL SP. Z O.O., ul. Grzybowska 87, 00-844 Warszawa. The Controller has appointed a Data Protection Officer, who can be contacted by email at: iod@elektroepilacja.pl or by post at: ELEKTROEPILACJA.PL SP. Z O.O., ul. Grzybowska 87, 00-844 Warszawa.

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The Controller acts in accordance with 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 (the “GDPR”, in Polish “RODO”), and in particular: properly protects Users’ personal data against unauthorised access by third parties, including by encrypting and archiving personal data, assessing personal data protection measures, and ensuring the confidentiality, integrity, availability and resilience of processing systems and services.


§ 2. Purposes and legal bases for processing personal data on the Website

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Using the Website’s features may involve the Controller collecting and processing Users’ personal data. User data entered on the Website is the property of the User. Information and data about Users are collected so that Users can use the Website’s features. The User data collected and processed by the Controller includes the following types of personal data: first name, last name, date of birth, contact phone number and email address — if the User is a natural person; company name, company address details and NIP number — if the User wishes to receive a VAT invoice (faktura VAT) confirming the purchase of goods or services through the Website. The Controller processes User data for the following purposes:

  • to enable the use of the Website’s features and the provision of services offered by the Website, in particular the sale of devices, probes, cosmetics and accessories, the provision of training and consultations, and other services offered by the Website, and to settle payments — in order to perform a contract concluded with the User or to take steps at the User’s request prior to concluding it (Article 6(1)(b) GDPR),

  • to conclude and perform contracts for the provision of electronic services offered on the Website, in particular maintaining and operating the User’s account, placing and fulfilling orders and training registrations and settling payments — in order to perform a contract concluded with the User or to take steps at the User’s request prior to concluding it (Article 6(1)(b) GDPR),

  • to comply with legal obligations imposed on the Controller, in particular for accounting, bookkeeping and tax purposes (Article 6(1)(c) GDPR),

  • for contact purposes, i.e. to receive and handle enquiries and requests sent via the contact form, by email, by phone, via chat or by other means of remote communication — on the basis of the Controller’s legitimate interest in responding to the enquiry (Article 6(1)(f) GDPR),

  • for the possible establishment, pursuit of or defence against claims, which is the Controller’s legitimate interest (Article 6(1)(f) GDPR),

  • for evidential and archival purposes, in particular to keep records of the Controller’s activities and to retain information in case of a legal need to prove facts, which is the Controller’s legitimate interest (Article 6(1)(f) GDPR),

  • for analytical purposes, in particular to study User satisfaction, tailor the Website’s offer to Users’ expectations and improve the quality of services, which is the Controller’s legitimate interest (Article 6(1)(f) GDPR),

  • to enable the Controller to offer its own goods and services directly to Users (direct marketing and remarketing), including tailoring them to the User’s needs through profiling, which, however, will not significantly affect the User’s situation or produce legal effects concerning them, which is the Controller’s legitimate interest (Article 6(1)(f) GDPR),

  • to receive commercial information about the Controller’s own goods or services by electronic means, or to receive marketing content via telecommunications terminal equipment (phone) — on the basis of the User’s consent (Article 6(1)(a) GDPR and Article 398(1) of the Polish Electronic Communications Law of 12 July 2024 (Prawo komunikacji elektronicznej)).

Direct marketing by the Controller using terminal equipment (in particular mobile and landline phones, tablets and computers) and automated calling systems to the phone number and email address provided by the User, consisting of receiving marketing messages about the Controller’s goods and services and the marketing campaigns it organises, as well as sending commercial information about goods or services offered by the Controller to the email address or phone number provided by the User, within the meaning of the Act of 18 July 2002 on the provision of electronic services (ustawa o świadczeniu usług drogą elektroniczną) and Article 398 of the Polish Electronic Communications Law of 12 July 2024 (Prawo komunikacji elektronicznej) (Dz.U. 2024, item 1221), is possible only if the User gives separate consent under Article 6(1)(a) GDPR. Providing data and consenting to its processing is voluntary. This consent may be withdrawn at any time — the User may opt out of receiving further commercial information at any time by calling the hotline number shown on the website or by contacting the company by email at: contact@elektroepilacja.pl or by sending a letter to the address given in § 1(3) or (4) above.

 

§ 3. User rights

The User has the following rights:

  • access to their data and to a copy of it,

  • rectification (correction) of their data,

  • erasure of their data — if the User believes that the Controller has no grounds to process it,

  • restriction of processing — if the User believes that the Controller holds inaccurate data about them or is processing it without grounds; or if the User does not want the data erased because it is needed to establish, pursue or defend claims; or for the time it takes to consider an objection the User has raised to the processing of their data,

  • objection to the processing of their data for direct marketing purposes, including profiling, as well as the right to object to processing based on legitimate interest for purposes other than direct marketing,

  • data portability — the User has the right to receive from the Controller, in a structured, commonly used and machine-readable format, the personal data they have provided to the Controller on the basis of a contract or consent; the User may also instruct the Controller to transmit this data directly to another entity,

  • lodging a complaint with a supervisory authority — if the User believes that the Controller is processing their data unlawfully, they may lodge a complaint with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych) or with another competent supervisory authority,

  • withdrawal of consent to the processing of personal data — the User has the right to withdraw, at any time, their consent to the processing of personal data that the Controller processes on the basis of that consent; withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.

The User provides all data voluntarily and knowingly.

 

 

 

§ 4. Data recipients and transfers of data to third countries or international organisations

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The following categories of entities may have access to the User’s personal data:

  • authorised employees and associates of the Controller,

  • partners cooperating with the Controller who, depending on the nature of the cooperation, may also be independent data controllers,

  • service providers that supply the Controller with technical and organisational solutions enabling it to provide services and ensure functionality (in particular providers of courier and postal services, IT services and marketing services, providers of legal and consultancy services, and their authorised employees and associates),

  • entities that analyse data for the purpose of personalising advertising, which are independent controllers in this respect, in particular Google LLC; further information on data protection can be found at: https://policies.google.com/privacy,

  • authorised public authorities — on the basis of the relevant legal provisions, in particular in connection with combating fraud and abuse.

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Except in the cases described above, the Controller will not transfer, or allow the transfer of, personal data provided by the User outside the EEA (European Economic Area) unless it has taken the measures necessary to ensure that such a transfer complies with the GDPR. Such measures may include, in particular, transferring personal data to a recipient in a country that, according to a decision of the European Commission, ensures an adequate level of personal data protection (including recipients in the United States that participate in the EU-U.S. Data Privacy Framework), or transferring personal data on the basis of standard contractual clauses approved by the European Commission.

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In running the Website, the Controller uses Google services, and Google is an independent controller of Users’ personal data. The Controller promotes its products and services using Google Ads. The data collected about Users helps to target the Website owner’s advertising and promotion more precisely and is also used to develop remarketing campaigns. The Controller makes particular efforts to encourage Users to visit the Website. To improve its services and develop the Website, it therefore collects anonymised information about the User’s technical profile using Google Analytics.

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The Controller may also collect statistical data on the popularity and use of individual services offered by the Website and share it with other entities. This data will only be provided in anonymous, aggregated form, making it impossible to identify Users’ personal data from it. The Controller may also use the collected statistical data for marketing, informational and statistical purposes, and for publication in media such as the internet, the press, radio, television, and mobile and landline telephony.

 

§ 5. Processing of minors’ data

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The Website is not designed for or addressed to persons under 16 years of age.

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§ 6. Data retention period

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Personal data provided by the User will be processed for as long as necessary to achieve the purposes for which it was collected. The data retention period is not strictly defined and depends on many factors, including the User’s decisions regarding the use of the Website’s services. However, this period will not exceed:

  • for data processed in connection with the performance of contracts concluded with the Controller — the term of those contracts and, after their termination, the period resulting from the statutory limitation periods, i.e. a maximum of 6 years from the date the contract ended,

  • for data processed to comply with legal obligations imposed on the Controller, in particular under tax and accounting law — the period and scope required by law, but no more than 5 years from the date the contract ended,

  • for data processed on the basis of the Controller’s legitimate interest — until those interests have been fulfilled or until the User objects to such processing,

  • for data processed on the basis of the User’s consent — until the User withdraws that consent.


§ 7. Cookies

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The Website automatically collects only the information contained in the cookies described below. As a result of using the Website, text files (known as cookies) may be stored on the User’s devices to make it easier for the User to access and use the Website. Cookies are also used to study the User’s preferences and behaviour, which makes it possible to deliver personalised content on the Website and improve its performance. Data collected by cookies is also used for statistical purposes. In accordance with Article 399 of the Polish Electronic Communications Law of 12 July 2024 (Prawo komunikacji elektronicznej), cookies other than those necessary for the Website to function (in particular analytics and marketing cookies) are stored on the User’s device only with the User’s consent, which may be withdrawn at any time.

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The User can disable the placement and storage of cookies in their web browser. How to disable cookies depends on the User’s browser. Detailed information on the options and methods for handling cookies is available in the software (web browser) settings.

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Information on managing cookies in individual browsers can be found on the dedicated pages of those browsers. The Company may collect two types of cookies: “session” and “persistent” cookies. “Session” cookies are temporary files that remain on the User’s device until they log out of their account on the website or close the browser. “Persistent” cookies remain on the device for the time specified in the cookie parameters or until the User deletes them manually.

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Cookies placed on the Website User’s terminal device may also be used by advertisers and partners cooperating with the Controller. Cookies may be used to display advertising that reflects how the User uses the Website. The User can view and edit the information obtained from cookies using available online tools.

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The Controller advises that restricting the use of cookies may affect some of the features available on the Website and, in extreme cases, may make it impossible to use the Website.


 

§ 8. Changes to the Privacy Policy

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The Controller reserves the right to update and amend this Privacy Policy, in particular in response to developments in internet technology, changes in personal data protection law or the development of the Website. Users will be informed of any changes in a clear and understandable way so that they are aware of the amendments made.

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