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1. Definitions:

1.1. Administrator or FreedomBrands.pl – Freedom Brands sp.zo.o. based in Wrocław, address: Stanisława Leszczyńskiego 4 / 25, 50-078 Wrocław, entered into the register of entrepreneurs of the National Court Register kept by the District Court in Wrocław, KRS under KRS number 0000874757, REGON 387758381, NIP 8971886944,

1.2. Personal data - information about a natural person identified or identifiable by one or more specific factors determining the physical, physiological, genetic, mental, economic, cultural or social identity, including device IP, location data, online identifier and information collected via cookies and other similar technology.

1.3. Policy - this Privacy Policy, containing information on the processing of Personal Data and the use of cookies and similar tracking technologies within the Website.

1.4. GDPR - 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.

1.5. Website – website run by the Administrator in the domain https://freedombrands.pl, available via web browsers

1.6. Store - FreedomBrands online store available via the Website, through which FreedomBrands sells goods remotely.

1.7. User – any natural person visiting the Website or using one or more services or functionalities described in the Policy.

1.8. Device – means an electronic device through which the User gains access to the Website.

2. General information:

2.1. In connection with your use of the Website, we collect data needed to provide the services offered, as well as information about your activity on the Website. In this respect, we are the administrator of your Personal Data and we attach great importance to their proper protection. We make sure that our data processing processes are consistent with the relevant legal provisions, in particular the GDPR. Our goal is to provide you with full information regarding our processing of your Personal Data and to provide you with tools that allow you to exercise your rights. Below we provide information on how we process your Personal Data.

2.2. We process your Personal Data in accordance with the law, ensuring that they remain current and correct. Therefore, from time to time we may remind you about the need to update them by sending a message to the e-mail address you provided or by displaying an appropriate message on the Website after logging in to your account.

3. How can I contact the Administrator and the IOD?

    3.1. If you have any questions related to our processing of your Personal Data or want to exercise your rights, please write directly to our Data Protection Officer at the e-mail address ios@freedombrands.pl or to the address of our headquarters (Stanisława Leszczyńskiego 4 / 25, 50-078 Wrocław), alternatively use the contact form. Our Data Protection Officer is Dorota Przybylska.

    4. How do we obtain your personal data?

    4.1. We obtain your Personal Data directly from you in order to properly provide our services and ensure the efficient operation of our Website. You provide us with your data primarily through dedicated forms when you make purchases in our Store, run on the basis of the Store Regulations, subscribe to our newsletter or contact us, e.g. via the contact form. We also receive your data when you use other services available on the Website, e.g. you browse products offered in the Store.

    5. Is providing personal data mandatory?

      5.1. It is up to you to decide whether and what Personal Data you provide us with - it is not obligatory. Remember, however, that in some cases, providing Personal Data is necessary for the proper implementation of the services we offer or conditions the conclusion and performance of a contract, which we describe in detail below.

      6. How do we process your personal data?

      USING THE WEBSITE

      6.1. When you use the Website and you are not a registered User (i.e. you do not have an account on the Website), your Personal Data (including the IP address or other identifiers and information collected via cookies or other similar technologies) are processed by us:

      6.1.1. in order to provide services electronically in the scope of providing you with content collected on the Website - then the legal basis for processing is the necessity of processing to perform the contract (Article 6(1)(b) of the GDPR);

      6.1.2. for analytical and statistical purposes - then the legal basis for processing is the legitimate interest of the Administrator (Article 6(1)(f) of the GDPR), consisting in conducting analyzes of Users' activities as well as their preferences in order to improve the functionalities used and the services provided;

      6.1.3. in order to possibly determine and pursue claims or defend against claims - the legal basis for processing is the legitimate interest of the Administrator (Article 6(1)(f) of the GDPR), consisting in the protection of his rights and economic interests;

      6.1.4. for the marketing purposes of the Administrator and other entities, in particular related to the presentation of behavioral advertising - the principles of processing Personal Data for marketing purposes are described in the MARKETING section.

      6.2. Your activity on the Website, including your Personal Data, is recorded in system logs (a special computer program used to store a chronological record containing information about events and activities that concern the IT system used to provide our services). The information collected in the logs is processed primarily for purposes related to the provision of services. We also process them for technical and administrative purposes, to ensure the security of the IT system and to manage this system, as well as for analytical and statistical purposes - in this respect, the legal basis for processing is the legitimate interest of the Administrator (Article 6(1)(f) of the GDPR). ).


      REGISTRATION AND ACCOUNT SERVICE

      6.3. People who register on the Website are asked to provide the data necessary to create and operate an account. To facilitate use, you can provide additional data, thereby consenting to their processing. Such data can be deleted at any time. Providing data marked as mandatory is required to create and operate an account, and failure to provide them results in the inability to create an account. Providing other data is voluntary.

      6.4. Your Personal Data is processed:

      6.4.1. in order to provide services related to maintaining and servicing an account on the Website - the legal basis for processing is the necessity of processing to perform the contract (Article 6(1)(b) of the GDPR), and in the scope of optional data - the legal basis for processing is consent (Article 6 section 1(a) of the GDPR);

      6.4.2. for analytical and statistical purposes - the legal basis for processing is the legitimate interest of the Administrator (Article 6(1)(f) of the GDPR), consisting in conducting analyzes of Users' activity on the Website and the method of using the account, as well as Users' preferences in order to improve the functionalities used ;

      6.4.3. in order to possibly determine and pursue claims or defend against claims - the legal basis for processing is the legitimate interest of the Administrator (Article 6(1)(f) of the GDPR), consisting in the protection of his rights and economic interests;

      6.4.4. for marketing purposes of the Administrator and other entities - the principles of processing Personal Data for marketing purposes are described in the MARKETING section.

      6.5. If the User posts any Personal Data of other persons on the Website (including their name and surname, address, telephone number or e-mail address), he or she may do so only provided that the law and personal rights of these persons are not violated.


      PLACING ORDERS

      6.6. Placing an order for goods or services offered by us involves the processing of your Personal Data. Providing data marked as mandatory is required to accept and process the order, and failure to provide it will result in the order not being processed. Providing other data is optional.

      6.7. Your Personal Data is processed:

      6.7.1. in order to fulfill the placed order - the legal basis for processing is the necessity of processing to perform the contract (Article 6(1)(b) of the GDPR); in the scope of optional data, the legal basis for processing is your consent (Article 6(1)(a) of the GDPR);

      6.7.2. in order to fulfill the statutory obligations imposed on the Administrator, resulting in particular from tax regulations and accounting regulations - the legal basis for processing is the legal obligation (Article 6(1)(c) of the GDPR);

      6.7.3. for analytical and statistical purposes - the legal basis for processing is the legitimate interest of the Administrator (Article 6(1)(f) of the GDPR), consisting in conducting analyzes of Users' activity on the Website, as well as Users' purchasing preferences in order to improve the functionalities used;


      COMPLAINTS AND RETURNS

      6.8. Submitting a complaint or return involves the processing of your Personal Data. Providing data in the complaint form is not obligatory, but necessary for the proper consideration of the complaint. Providing data in the return form is not obligatory, but necessary for effective withdrawal from the contract.

      6.9. Your Personal Data is processed:

      6.9.1. in order to consider a submitted complaint - the legal basis for the processing of your Personal Data is the Administrator's obligation resulting from the legal provisions regarding the warranty for defects in the sold goods (Article 6(1)(c) of the GDPR);

      6.9.2. in order to handle the return - the legal basis for the processing of your Personal Data is the Administrator's obligation arising from the provisions of consumer law (Article 6(1)(c) of the GDPR), if the basis for the return is the provisions on the right to withdraw from the contract or the necessity of processing to perform the contract ( Article 6(1)(b) of the GDPR), if the basis for the return is the regulations of our Store;

      6.9.3. in order to fulfill other statutory obligations imposed on the Administrator, resulting in particular from tax regulations and accounting regulations - the legal basis for processing is the legal obligation (Article 6(1)(c) of the GDPR);

      6.9.4. for analytical and statistical purposes - the legal basis for processing is the legitimate interest of the Administrator (Article 6(1)(f) of the GDPR), consisting in conducting analyzes of Users' activity on the Website, as well as Users' purchasing preferences in order to improve the functionalities used;

      6.9.5. in order to possibly determine and pursue claims or defend against claims - the legal basis for processing is the legitimate interest of the Administrator (Article 6(1)(f) of the GDPR), consisting in the protection of his rights and economic interests.


      CONTACT FORM

      6/10. We provide the opportunity to contact us via the contact form. Using the form requires providing the Personal Data necessary to contact you and respond to your inquiry. Providing data marked as mandatory is required to accept and handle the inquiry, and failure to provide it results in the inability to process it. Providing other data (e.g. in the content of the inquiry) is voluntary.

      6/11. Your Personal Data is processed:

      6.11.1. in order to identify and handle your inquiry sent via the form provided - the legal basis for processing is the legitimate interest of the Administrator (Article 6(1)(f) of the GDPR), consisting in the need to resolve the reported matter and conduct correspondence addressed to him in connection with his activities economic;

      6.11.2. for analytical and statistical purposes - the legal basis for processing is the legitimate interest of the Administrator (Article 6(1)(f) of the GDPR), consisting in maintaining statistics of inquiries submitted by Users via the Website in order to improve its functionality.

      7. Marketing

      7.1. We process your Personal Data in order to carry out marketing activities, which may include:

      7.1.1. displaying marketing content corresponding to your interests (behavioral advertising);

      7.1.2. conducting activities related to direct marketing of goods and services (sending commercial information by electronic means and telemarketing activities).

      7.2. In some cases, we use profiling to carry out marketing activities. This means that, thanks to automatic data processing, we evaluate selected factors relating to you in order to analyze your behavior or create a forecast for the future. This allows you to better tailor the displayed content to your individual preferences and interests.


      BEHAVIORAL ADVERTISING

      7.3. Together with our trusted partners, we process your Personal Data, including Personal Data collected via cookies and other similar technologies, for marketing purposes in connection with directing behavioral advertising to you (i.e. advertising that is tailored to your preferences). The processing of Personal Data also includes profiling, but its consequence is only the display of a tailored advertisement based on your Personal Data obtained by us and our partners.


      DIRECT MARKETING

      7.4. If you consent, your data may be used by us to send marketing content to you via various channels, i.e. via e-mail (in the form of a newsletter), via MMS / SMS or by phone. The legal basis for the processing of your data in this case is the legitimate interest of the Administrator (Article 6(1)(f) of the GDPR) in connection with your consent, consisting in the marketing of the offered goods and services. We only take such actions if you give us your consent, which you can withdraw at any time. You can withdraw your consent at any time by clicking on the link we send in each e-mail containing commercial information, by contacting us at the e-mail address: hello@freedombrands.pl or using the contact form. Withdrawal of consent does not affect the correctness of data processing in the period before its withdrawal.


      GOOGLE ADS CUSTOMER MATCH

      7.5. Marketing of the products and services we offer can be done using the Google Ads Customer Match tool. Google Ads Customer Match is a tool that allows the Administrator to load a hashed database of e-mail addresses (customer list) into Google tools in order to check whether user accounts have been created in Google services using the same e-mail addresses (e.g. YouTube, Gmail, other). If the matching of e-mail addresses is confirmed, the Administrator's advertisements may be displayed to users of Google services after logging in.


      FACEBOOK CUSTOM AUDIENCE

      7.6. Marketing of the products and services we offer can be done using the Facebook Custom Audience tool. Facebook Custom Audience is a tool that allows the Administrator to load a hashed database of e-mail addresses into Facebook tools in order to check whether user accounts have been created on the Facebook platform using the same e-mail addresses. If the correspondence of e-mail addresses is confirmed, the Administrator's advertisements may be displayed to Facebook users after logging in. More information about custom audiences can be found here: https://pl-pl.facebook.com/business/help/341425252616329?id=2469097953376494

      8. Social networking sites

      8.1. We process Personal Data of people visiting our profiles on social media (Facebook, Instagram, Pinterest, TikTok). Information about processing

      9. Information about the use of cookies

      WHAT ARE COOKIES?

      9.1. Cookies (also known as "cookies") are small text files saved and stored on devices through which the User uses the Website. Cookies collect information that facilitates the use of the Website - e.g. by remembering the User's visits and activities performed by him. The cookies we use are safe for the User's Device. In particular, this way it is not possible for viruses or other unwanted software or malware to penetrate Users' Devices. These files allow you to identify the software used by the User and adapt the operation of the Website individually to each User.


      TYPES OF COOKIES USED BY THE ADMINISTRATOR

      9.2. We use the following types of cookies:

      9.2.1. Required cookies are necessary for the proper functioning of the Website. Thanks to these files, the Administrator can ensure that such activities are carried out in a safe manner, such as fulfilling the User's order, "remembering" the logged-in User on the Website after switching to another website, or automatically completing address data when shopping. Blocking these cookies in the User's browser may result in incorrect operation of the Website. These cookies are required and it is not possible to deactivate them.

      Specific purposes of using technical cookies:

      1. a) ensuring the security and reliability of the Website;
      2. b) implementation of processes necessary to ensure full functionality of the Website, including:
      • adapting the content of the Website in order to ensure that the User can fully use the available functionalities and optimize the use of the Website's websites. In particular, these files allow you to recognize the basic parameters of the User's Device and properly display the website;
      • correct operation of the "Recommend to a friend" program, in particular enabling verification of the sources of User redirection to the Website;
      • enabling the use of the "Clipboard" and "Cart" functions on the Website.

      9.2.2. Analytical cookies are used by the Administrator both to analyze Users' behavior on the Website for business purposes and to understand how Users use the Website. This allows you to identify which functionalities require improvement or updating. The information obtained by the Administrator via analytical cookies is anonymous - on their basis, the Administrator is not able to identify the User from whom the information was obtained.

      9.2.3. Personalization cookies enable the analysis of Users' behavior on the Website and their purchasing preferences, which allows them to provide Users with personalized product suggestions, make changes to the functionality of the Website and post sponsored content. Data obtained through this type of cookies may also be used to improve existing systems and software and develop new solutions and functionalities.

      9.2.4. Advertising cookies allow the Administrator to adapt the displayed advertisements to the preferences and interests of Users, i.e. to direct the so-called behavioral advertising. With their help, entities cooperating with the Administrator, such as Facebook or Instagram website operators, will be able to properly adjust the displayed advertising content to suit the User's preferences.


      COOKIES STORAGE PERIOD

      9.3. The cookies described above can be divided into two types depending on their storage period:

      9.3.1. Session cookies are stored on the User's Device and remain there until the end of the browser session. The saved information is then permanently deleted from the Device's memory.

      9.3.2. Persistent cookies are stored on your Device until you delete them. Ending a given browser session or turning off the Device does not delete them. If the User does not delete persistent cookies from his/her Device, they will be stored for up to 60 days from their introduction.


      MANAGING COOKIES ON THE WEBSITE

      9.4. Only required cookies are necessary for the Website to function properly. For other types of cookies, you can consent to their use, but it is not obligatory. You can manage our use of analytical, personalization and advertising cookies by giving or withdrawing your consent to their use. You can manage consent to particular types of cookies at any time using the panel we provide. The panel can be accessed via the "Your cookies" tab located in the footer of the Website.


      OUR PARTNERS

      9.5. Some cookies are placed on the Website by external entities - partners cooperating with us. The current list of partners with whom we cooperate in the use of cookies, along with the categories of cookies they set, can be found in the table below. Detailed information in this regard can be found in the privacy policy of a given partner.

      Facebook, Google Ads - Advertising

      Google Analytics – Analytics

      10. Who will we transfer your personal data to?

      10.1. We may transfer your Personal Data to entities with which we cooperate in the provision of the services we provide.

      10.2. Depending on the method of delivery or return of purchased goods you choose, we will provide your data necessary for the delivery or return of goods to one of the entities with which we cooperate in this area. If you use the geolocation service to search for stationary delivery points, your Personal Data will also be transferred to entities providing location services.

      10.3. Depending on the payment method you choose for the purchased goods, we will transfer your data necessary to collect or make payment to one of the entities with which we cooperate in the field of payment processing.

      10.4. If you agree to receive commercial information at the e-mail address or telephone number provided by you, we will transfer your data to entities providing commercial information sending services on our behalf.

      10.5. In addition, your data will be transferred to entities that, on our behalf, process customers' Personal Data to the extent necessary for hosting the Store's websites.

      10.6. We may also transfer your Personal Data to other entities with which we establish cooperation, including legal and tax advisors, as well as those providing accounting, IT, logistics and marketing services.

      10.7. We also have the right to disclose selected information about our Users to competent authorities or third parties who request such information, based on an appropriate legal basis and in accordance with applicable law.

      11. How long will we process your personal data?

      11.1. The period of time we process your data depends on the type of service provided and the purpose of processing. As a rule, data is processed for the duration of the provision of the service or execution of the order, until the consent is withdrawn or an effective objection to data processing is raised in cases where the legal basis for data processing is the legitimate interest of the Administrator.

      11.2. The data processing period may be extended if processing is necessary to establish and pursue possible claims or defend against claims, and after that time only if and to the extent required by law. After the processing period, the data is irreversibly deleted or anonymized.

      12. What rights do you have in connection with the processing of your personal data?

      12.1. In connection with our processing of your Personal Data, you have the following rights:

      12.1.1. the right to information about the processing of Personal Data - on this basis, the Administrator provides you with information about the processing of your Personal Data, including, in particular, the purposes and legal basis for processing, the scope of data held, the entities to which it is disclosed and the planned date of data deletion;

      12.1.2. the right to obtain a copy of the data - on this basis, the Administrator provides you with a copy of your Personal Data processed by him;

      12.1.3. the right to rectification - the Administrator is obliged to remove any possible inconsistencies or errors in the processed Personal Data and supplement them if they are incomplete;

      12.1.4. the right to delete data - on this basis you can request the deletion of data whose processing is no longer necessary to achieve any of the purposes for which it was collected;

      12.1.5. the right to limit processing - if such a request is made, the Administrator ceases to perform operations on your Personal Data - except for the operations to which you have consented and to store data, in accordance with the adopted retention principles - or until the reasons for limiting data processing cease to exist (e.g. . a decision of the supervisory authority will be issued authorizing further data processing);

      12.1.6. the right to transfer data - on this basis - to the extent that the data is processed in an automated manner in connection with the concluded contract or consent - the Administrator issues the data provided by you in a format that allows the data to be read by a computer. It is also possible to request that this data be sent to another entity, provided that there are technical possibilities in this respect, both on the Administrator's side and on yours;

      12.1.7. the right to object to the processing of data for marketing purposes - you can object to the processing of your Personal Data for marketing purposes at any time, without the need to justify such objection;

      12.1.8. the right to object to other purposes of data processing - you can object at any time - for reasons related to your particular situation - to the processing of your Personal Data which is carried out on the basis of the legitimate interest of the Administrator (e.g. for analytical or statistical purposes or for reasons related to protection of property); objections in this respect should include justification;

      12.1.9. the right to withdraw consent - if the data is processed on the basis of your consent, you have the right to withdraw it at any time, which, however, does not affect the lawfulness of the processing carried out before its withdrawal;

      12/1/10. the right to complain - if you believe that the processing of Personal Data violates the provisions of the GDPR or other provisions regarding the protection of Personal Data, you may submit a complaint to the authority supervising the processing of Personal Data, competent for your place of habitual residence, place of work or place of the alleged violation. In Poland, the supervisory authority is the President of the Personal Data Protection Office (ul. Stawki 2, 00-193 Warsaw).


      SUBMITTING REQUESTS RELATED TO THE EXERCISE OF RIGHTS

      12.2. You can exercise some of the above rights yourself. If you have an account in the Store, you always have access to your Personal Data and can correct and update it.

      12.3. You can submit a request regarding all of the above rights by contacting our Data Protection Officer at the following e-mail address: ios@freedombrands.pl (this e-mail address is not used to send cooperation and marketing offers, such messages will be ignored by our reporting system) or to the address of our headquarters (Stanisława Leszczyńskiego 4 / 25, 50-078 Wrocław), as well as using our contact form.

      12.4. We will try to fulfill your request as quickly as possible and answer your questions regarding the processing of your data. You will receive a response within 30 days of our receipt of your request. If it turns out that due to the complexity of the request or the number of requests we have received, we are unable to provide you with information about the actions taken within this deadline, we will inform you about its extension.

      12.5. If we have doubts as to whether you are the one making a specific request, we may ask you a few additional questions to verify your identity. Providing such data is not obligatory, but failure to provide it will result in the request being refused. We may also need additional information to determine the exact content of your request.

      12.6. The request may be submitted in person or through a representative (e.g. a family member). For data security reasons, we encourage you to use a power of attorney in a form certified by a notary or an authorized legal advisor or attorney, which will speed up the verification of the authenticity of the request.

      12.7. If the request is sent to us electronically, we will respond in the same form, unless the applicant requests a response in a different form. In other cases, we will respond in writing. If the deadline for fulfilling the request makes it impossible to respond in writing, and the scope of the applicant's data processed by us allows contact by electronic means, we will provide a response electronically.

      12.8. We store information regarding the submitted request and the person who submitted the request in order to ensure compliance and to establish, defend or pursue possible claims of data subjects. The request register is stored in a way that ensures the integrity and confidentiality of the data contained therein.

      13. Changes to the privacy policy

      13.1. The policy is verified on an ongoing basis and updated, if necessary. The current version of the Policy has been adopted and is valid from August 2021.