Privacy Policy

This Privacy and Cookies Policy (hereinafter “Privacy Policy”) specifies the principles of processing and protection of personal data collected by the Administrator as part of the use by users (hereinafter “Users”) of the Innwell.pl online store and related services (hereinafter “Website”), as well as the use of cookies in connection with the Service.

1. PERSONAL DATA CONTROLLER

The personal data controller is Innwell spółka z ograniczoną odpowiedzialnością with its registered office in Poznań (60-451) at ul. Jana Henryka Dąbrowskiego 506/113, entered into the National Court Register under KRS number 0000626697, with NIP: 7811930340 and share capital of PLN 100,000.00. The Administrator can be contacted in writing at the registered office address indicated in the preceding sentence, as well as by e-mail at biuro@innwell.pl.

1. PURPOSES AND LEGAL BASIS FOR PROCESSING

Personal data are processed by the Administrator in accordance with the provisions of the law, including 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 (hereinafter referred to as “GDPR”) for the purpose of:

1. establishing commercial relations, including providing answers to questions asked in connection with the contact of persons (based on art. 6 sec. 1 letter f of the GDPR);
2. implementing the contract for the provision of services concluded on the terms specified in the Regulations of innwell.pl (based on art. 6 sec. 1 letter b of the GDPR);
3. fulfilling the legal obligations incumbent on the Administrator resulting from accounting and tax regulations (based on art. 6 sec. 1 letter c of the GDPR);
4. pursuing the legitimate interest of the Administrator in pursuing or securing claims (based on art. 6 sec. 1 letter f of the GDPR);
5. pursuing the legitimate interest of the Administrator in the scope of marketing of own goods or services (pursuant to art. 6 sec. 1 letter f of the GDPR);
6. analyzing network traffic, ensuring security when using the Service and adapting content to the needs of Users based on the legitimate interest of the Administrator (pursuant to art. 6 sec. 1 letter f of the GDPR).

PRINCIPLES OF PERSONAL DATA PROCESSING

1. The Administrator processes personal data only to the minimum extent necessary to achieve the purposes for which they are collected. The purposes and grounds for collecting personal data are clearly defined in this Privacy Policy. The Administrator does not process personal data in a manner inconsistent with these purposes.
2. Providing data on the Service pages is voluntary, however, the consequence of not providing it may be the inability of the User to use the service, including concluding an agreement for the provision of services on the terms specified in the Regulations of the innwell.pl online store.
3. The Administrator does not process personal data in a manner that would involve making only automated decisions regarding the person whose data it concerns.
4. If the User enters third-party data in the Service for the purposes of communication, recommendations, or using the Administrator’s services, the User should have the right to enter such third-party data in the Service, for example, have the appropriate consent of the third party and fulfill the secondary information obligation on behalf of the Administrator regarding the data of persons obtained other than from the person concerned (in accordance with Article 14 of the GDPR).

RIGHTS OF DATA SUBJECTS

1. A person whose personal data is processed by the Administrator in accordance with the provisions of law has the right to:
2. access the content of their data;
3. rectify personal data;
4. limit the processing of personal data;
5. delete personal data;
6. transfer data;
7. withdraw consent in the event that the Administrator processes personal data based on the User’s consent, at any time and in any manner, without affecting the lawfulness of the processing carried out on the basis of consent before its withdrawal;
8. The exercise of the rights referred to in the preceding sentence may be carried out by sending an appropriate request to the Administrator’s e-mail address (indicated in point 1) along with the name, surname and e-mail address of the person exercising such right.
9. The data subject has the right to lodge a complaint with the President of the Personal Data Protection Office if he or she considers that the processing of personal data by the Administrator violates the provisions of applicable law.

RECIPIENTS OF PERSONAL DATA

1. Personal data may be transferred to trusted recipients with whom the Administrator cooperates, such as such as: an entity providing accounting services, partners providing technical services (development and maintenance of IT systems and websites), marketing agencies, debt collection companies. The transfer and processing of personal data is carried out in accordance with our instructions, privacy protection principles and all other appropriate measures to protect confidentiality and security.
2. Personal data may be transferred to entities authorized to receive them under applicable law, including competent state authorities, in particular judicial authorities.
3. Personal data may be transferred to entities indicated in point 7, paragraph 7 (including to a third country). Regardless of the above, personal data may be transferred to a third country or an international organization, if this does not conflict with applicable law. Transfer to other recipients in third countries (outside the European Economic Area) may take place on the basis of a decision on the adequacy of protection taken by the European Commission or on the basis of standard contractual clauses, in accordance with the decision of the European Commission or on the basis of the express consent of the data subject.

DATA STORAGE PERIOD

1. The Administrator limits the storage of personal data in accordance with the provisions of law, only to the period necessary to achieve the purposes for which they are collected, unless there are rational reasons allowing for the extension of the data storage period.
2. Personal data processed for the purposes of marketing own products or services based on a legitimate legal interest will be processed until the data subject objects.

COOKIES

1. The Administrator uses cookies or similar technologies (hereinafter collectively referred to as “cookies“), which should be understood as IT data, in particular text files, intended for using pages in the innwell.pl domain and stored in the end devices of users browsing pages in the innwell.pl domain.
2. Collection of data using cookies allows for customization of services and content to individual needs, as well as preferences of Users, i.e. people browsing websites on the Service, and is also used to develop general statistics regarding the use of the Service.
3. The information collected concerns the IP address, type of browser used, language, type of operating system, Internet service provider, information about time and date, location and information sent to the website via the contact form.
4. Data collected using cookies is collected solely for the purpose of performing specific functions for Users and is encrypted in a way that prevents access by unauthorized persons.
5. The Administrator uses, as a rule, two types of cookies with regard to the time for which the cookie lasts – “session” and “persistent“:
6. session cookies are temporary files that remain on the User’s device until logging out, leaving the website or turning off the software (internet browser);
7. persistent cookies are files that remain on the User’s device for the time specified in the cookie parameters or until they are manually deleted by the User, the following types of cookies.
8. The Administrator uses, as a rule, the following cookies due to their necessity to provide services:
9. “necessary” cookies, enabling the use of services available within the Service, e.g. authentication cookies used for services that require authentication within the Service;
10. “performance” cookies, enabling the collection of information on how the Service’s web pages are used;
11. “functional” cookies, enabling the “remembering” of settings selected by the User and personalizing the User interface, e.g. in terms of the selected language or region the User comes from, font size, appearance of the website, etc.;
12. “advertising” cookies, enabling the provision of advertising content to Users that is more tailored to their interests.
13. The Administrator uses cookies from external suppliers:
14. Google Analytics – files used by Google enabling the analysis of the User’s use of the Service from the website. Detailed information on the scope and principles, including exclusion, of data collection in connection with this service can be found at the following link: https://support.google.com/analytics/answer/6004245?hl=pl;
15. Facebook – used by Facebook to provide advertising services.
16. Google Ads Remarketing – files used by Google to address Users with targeted advertising on Google partner network sites. Detailed information on the scope and principles, including exclusion, of data collection in connection with this service can be found at the link: https://www.google.plpolicies/privacy/;
17. Google Tag Manager – a Google tool used to manage website tags. This service does not use any cookies and does not collect any personal data.
18. In many cases, software used to browse websites (internet browser) allows cookies to be stored on the User’s end device by default. Users of the Service can change their cookie settings at any time. These settings can be changed in particular in such a way as to block automatic handling of cookies in the web browser settings or to inform about each time they are placed on the Service User’s device. Detailed information about the possibilities and methods of handling cookies is available in the software (web browser) settings.
19. The Administrator informs that restrictions on the use of cookies may affect some functionalities available on the Service’s websites.
20. Cookies placed on the Service User’s end device and may also be used by advertisers and partners cooperating with the Service operator.