- The following Privacy Policy sets out the rules for saving and accessing data on the Devices of Users using the Website for the purposes of providing services electronically by the Administrator and the rules for collecting and processing Users’ personal data that were provided by them personally and voluntarily via the tools available on the Website.
The following Privacy Policy is an integral part of the Terms and Conditions, which defines the principles, rights and obligations of Users using the Website.
§1 Definitions
Website – “AllTech Interactive” website operating at https://sarugami.pl/.
External website – websites of partners, service providers or service recipients cooperating with the Administrator.
Website/Data Administrator – the Website Administrator and Data Administrator (hereinafter referred to as the Administrator) is the company “AllTech Interactive Sp. z o. o., operating at the following address: Wyścigowa St, Apt. 56E, 53-012 Wrocław under the KRS number: 0000835899 and REGON:385855909, with the assigned tax identification number (NIP): 8943152816, providing services electronically via the Website. The administrator determines why and how, processes your data. You can contact the administrator via e-mail: [email protected].
User – a natural person for whom the Administrator provides services electronically via the Website.
Device – an electronic device with software through which the User gains access to the Website.
Cookies (ciasteczka) – dane tekstowe gromadzone w formie plików zamieszczanych na Urządzeniu Użytkownika.
GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation)) 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 data).
Personal data – means information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Processing – means an operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collecting, recording, organizing, structuring, storing, adapting or modifying, downloading, viewing, using, disclosing by sending, disseminating or otherwise such sharing, alignment or combination, restriction, erasure or destruction.
Restriction of processing – means marking stored personal data in order to limit their future processing.
Profiling – means any form of automated processing of personal data, which consists in using personal data to evaluate certain personal factors of a natural person, in particular to analyze or predict aspects regarding the performance of that natural person, his or her economic situation, health, personal preferences, interests, reliability, behavior, location or movement.
Consent – consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which the data subject, by means of a statement or a clear affirmative action, signifies agreement to the processing of personal data concerning him or her.
Breach of personal data protection – means a breach of security leading to accidental or unlawful destruction, loss, modification, unauthorized disclosure or unauthorized access to personal data transmitted, stored or otherwise processed.
Pseudonymisation – means processing personal data in such a way that they can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that they are not attributed to an identified or identifiable natural person.
Anonymization – data anonymization is an irreversible process of data operations that destroys / overwrites “personal data”, making it impossible to identify or link a given record with a specific user or natural person.
§2 Data Protection Inspector
According to Article 37 of the RODO, the Administrator did not appoint a Data Protection Inspector.
In matters relating to data processing, including personal data, please contact the Administrator directly.
§3 Cookie Policy
2. All terms defined in the Privacy Policy retain their meaning also in this Cookies Policy. Too much, the following terms shall have the following meanings:
Internal cookies – files placed and read from the User’s Device by the Website’s IT system
External cookies – files placed and read from the User’s Device by the IT systems of external websites. Scripts of external websites that may place Cookies on User’s Devices have been consciously placed on the Website through scripts and services made available and installed on the Website
Session cookies – files uploaded to and read from the User’s Device by the Website or external services during one session of a given Device. After the session ends, the files are deleted from the User’s Device
Persistent cookies – files uploaded to and read from the User’s Device by the Website or external services until they are manually deleted. Files are not deleted automatically after the end of the Device session, unless the configuration of the User’s Device is set to the mode of deleting cookies after the end of the Device session
3. Purposes for which cookies are used:
- Improving and facilitating access to the Website
- Personalization of the Website for Users
- Enabling Login to the website
- Marketing, Remarketing on external websites
- Advertising serving services
- Affiliate services
- Maintaining statistics (users, number of visits, types of devices, connection, etc.)
- Serving multimedia services
- Providing community services
4. Purposes of personal data processing:
Personal data voluntarily provided by Users is processed for one of the following purposes:
- Implementation of electronic services:
- Registration and maintenance services for the User’s account on the Website and related functionalities
- Newsletter services (including sending advertising content with consent)
- Services for sharing information about content posted on the Website on social networking sites or other websites.
- The Administrator’s communication with Users on matters related to the Website and data protection
- As part of the documentation needed for order management and sales support
- Ensuring the legally justified interest of the Administrator
User data collected anonymously and automatically is processed for one of the following purposes:
- Keeping statistics
- Remarketing
- Serving advertisements tailored to Users’ preferences
- Affiliate program management
- Ensuring the legally justified interest of the Administrator
5. Cookies of external websites:
The Administrator of the Website uses web components of partners who may place their own cookies on the User’s Device. Remember that in your browser settings you can decide about allowed cookies that can be used by individual websites. Below is a list of partners or their services implemented on the Website that may place cookies: Below is a list of partners or their services implemented on the Website that may place cookies:
- Social/Combined Services:
(Registration, Login, Content Sharing, Communication, etc.)
- Keeping statistics:
Services provided by third parties are beyond the Administrator’s control. These entities may change their terms of service, privacy policy, purpose of data processing and methods of using cookies at any time.
§4 Security of data submission
Depending on what you do on the website or app, we may collect different sets of personal data.
Mechanisms for storing and reading Cookie files – the mechanisms for storing, reading and exchanging data between Cookie files saved on the User’s Device and the Website are implemented through built-in mechanisms of web browsers and do not allow downloading other data from the User’s Device or data from other websites visited by the User, including personal data or confidential information.
Thanks to your personal data, we receive the information necessary to complete the purchasing process.
When you visit our online store
If you are a person who already has an account with us and is logged in, we can identify you based on the data available in your account.
Whenever you visit our store via the website, we download cookies that are associated with your personal data.
- first name and last name,
- delivery address,
- e-mail address,
- phone number,
- invoice data, if required by the User.
Whenever you visit our store via the website, we download cookies that are associated with your personal data. We collect cookies that are necessary for the website to function properly, as well as those that are not mandatory but we have your consent to collect them, for example, an internet identifier – IP number.
When you register an account
When you create an account with us, you must provide the following data:
- first name and last name,
- e-mail address,
- account password.
This is a standard set of data for each individual. If you do not provide us with this data, we will not create an account in the store for you.
When you use your account
When you use your account you have access to the user panel where you can complete, check, and change data.
In your account, when you first order, you can save the following data:
- first name and last name,
- NIP,
- billing and shipping address,
- phone number,
- email address.
When you use your account, we collect additional information about you:
- purchase history,
- history of additional services,
- preferred and used payment methods,
- data you use to issue proof of purchase,
- shipping information,
- payment statuses,
- comments and opinions that relate to the transaction.
- You buy our products from our partners
You can also buy our products on other platforms. In this case, we receive your data from these platforms, which is necessary for us to complete your purchase and ship the product. We also receive any opinions and reviews submitted regarding products and/or transactions through these platforms.
- You pay for your purchases
When you pay cashless, you use services provided by our partners who process specific personal data that are necessary to complete the transaction.
When you use an email, call or chat to contact with us
You can contact us through various channels. Depending on the form of contact you choose, we will you for a different set of data.
You can contact:
- via e-mail address – you send an e-mail from your e-mail address, you provide us with your e-mail address and other data that you provide in the message,
- by phone – you provide us with your phone number and other data that the advisor will ask for in order to verify who you are talking to, solve the problem, or provide information about the order,
- via chat or other messenger – you provide us with your nickname and other data that you send.
Remember that as part of customer service – user, we can use the contact details provided added by you in the customer panel on your sagurami.pl account
We save chats and e-mails, we do this to handle the matter you report.
After meeting legal requirements, we process your data for marketing purposes if:
- You are signing up for the Newsletter
When you use our website, you can subscribe to the newsletter.
To send you the newsletter, we process your e-mail address provided during registration.
- You consent to the automated processing of your data, including profiling, or we use our legitimate interest of the administrator
You can consent to the automated processing of your data and profiling. This means that we will be able to process your data automatically. This means that we will be able to process your data automatically. This way we can, based on what you browse and buy:
- prepare an individual offer for you,
- prepare an individual newsletter for you,
- propose additional services or products
- display the individual product card,
- prepare a dedicated advertising campaign.
We may use our legitimate interest as an administrator to adapt the content we provide to you to your preferences and expectations. For this purpose, we use marketing tools for statistical and analytical purposes and examine the attractiveness of the offers we send to you.
Cookies on our website
When you visit our website, you receive information about cookies and can choose which ones we can download. The exception is cookies that are necessary for the website to function.
When you accept cookies on our website, we will collect the information specified in them for statistical and analytical purposes. Cookies may collect your IP address. We cannot identify you using your IP address alone, but when combined with other information we may be able to do so.
Detailed information on what data is stored in cookies and how we process it can be found in point 3.
When you express your opinion about a product, purchase, or store, you are participating in surveys
You can leave a review about purchases in our store, products purchased, and the store in general.
You will do this:
- mail or via our form, you provide us with your e-mail address and other
- under the product, on its page.
We analyze the results of these surveys in detail and based on them we improve our offer, and customer service and organize marketing campaigns.
In the survey, you will find a clause in which we inform you about what data we process. We will attach regulations to some surveys, which will be a template of the contract between you and us.
Processing of personal data in connection with the parties’ claims
We may process your personal data when we pursue our claims and rights or defend ourselves against claims you have submitted against us.
For this purpose, we will process data that is necessary to consider or defend against a claim.
We will process the data until the case is completed or the judgment becomes final. While your claim is being processed, we will not delete your data even if you request it.
[legal basis: art. 6 section 1 letter f GDPR]
Cookie control
The User may, at any time, independently change the settings for saving, deleting, and accessing data stored in Cookies by each website.
Information on how to disable cookies in the most popular computer browsers is available on the website: how to disable cookies or from one of the indicated providers:
The User may at any time delete all Cookie files saved so far using the tools of the User’s Device through which the User uses the Website’s services.
Threats on the User’s side – the Administrator uses all possible technical measures to ensure the security of data stored in cookies. However, it should be noted that ensuring the security of this data depends on both parties, including the User’s activity. However, it should be noted that ensuring the security of this data depends on both parties, including the User’s activity. The Administrator is not responsible for the interception of this data, impersonation of the User’s session, or their deletion as a result of the User’s conscious or unconscious activity, viruses, Trojan horses, and other spyware that may have infected the User’s Device. To protect themselves against these threats, users should follow the principles of safe use of the Internet.
- Storage of personal data – the Administrator ensures that he makes every effort to ensure that the processed personal data entered voluntarily by Users are safe, access to them is limited, and carried out by their purpose and processing purposes. The Administrator also ensures that it makes every effort to protect its data against loss by using appropriate physical and organizational security measures.
- Password storage – the Administrator declares that passwords are stored in encrypted form, using the latest standards and guidelines in this regard. The decryption of account access passwords provided on the Website is practically impossible.
§5 Types of data collected
The website collects data about Users. Some of the data is collected automatically and anonymously, and some of the data is personal data provided voluntarily by Users when signing up for individual services offered by the Website.
Anonymous data collected automatically:
- IP address
- Browser type
- Screen resolution
- Approximate location
- Opened website subpages
- Time spent on the appropriate subpage of the website
- Type of operating system
- Address of the previous subpage
- Referrer address
- Browser language
- Internet connection speed
- Internet service provider
Data collected during registration:
- Name / surname / nickname
- Login
- E-mail address
- IP address (collected automatically)
Data collected when subscribing to the Newsletter service
- Name / surname / nickname
- E-mail address
- Latest activity
- IP address (collected automatically)
Data collected when adding a comment:
- Name and surname / nickname
- E-mail address
- Website address (if added on an external platform)
- Comment content
- IP address (collected automatically)
Some data (without identifying data) may be stored in cookies. Some of the data is collected automatically and anonymously, and some of the data is personal data provided voluntarily by Users when signing up for individual services offered by the Website.
§6 Access to personal data by third parties
As a rule, the only recipient of personal data provided by Users is the Administrator. Data collected as part of the services provided are not transferred or resold to third parties.
Access to data (usually on the basis of a Data Processing Agreement) may be granted to entities responsible for maintaining the infrastructure and services necessary to run the website:
- hosting companies providing hosting or related services to the Administrator,
- companies acting as intermediaries in online payments for goods or services offered on the Website (in the case of a purchase transaction on the Website),
- companies responsible for delivering physical products to the User (postal/courier services in the case of a purchase transaction on the Website),
- companies providing services in the field of sales system integration and issuing accounting documents – to the extent necessary to execute orders and process transactions,
- companies providing services in the field of issuing accounting documents – to the extent necessary to execute orders and process transactions,
- companies providing, with prior consent, services related to sending newsletters and conducting mailing campaigns.
- companies providing web analytics and online marketing services, including providers of advertising and statistical tools.
Entrusting the processing of personal data – Hosting Services, VPS, or Dedicated Servers
To run the website, the Administrator uses the services of an external hosting provider, VPS, or Dedicated Servers. All data collected and processed on the website are stored and processed in the service provider’s infrastructure located in Poland. It is possible to access data as a result of service work carried out by the service provider’s staff. Access to this data is regulated by the contract concluded between the Administrator and the Service Provider.
Data processing in the case of online payments
In the case of online payments, all payment data is provided directly by the User to the entity making the payment. Selected data necessary to complete the transaction are then transferred by this entity to the Administrator. The transfer of data is regulated by an agreement concluded between the Administrator and the Service Provider (more information can be found here: https://www.ingksiegowosc.pl/ochrona-danych-osobowych).
Transfer of personal data – Courier Services
In the event of concluding a transaction that requires the transfer of the item concerned by post or courier, part of the personal data of natural persons or data of natural persons running a business is transferred to the entity providing postal/courier services to the Administrator, selected by the User. The transfer of this data is regulated by the agreement concluded between the Administrator and the Service Provider (more information can be found here: https://www.dpd.com/pl/pl/polityka-prywatnosci/ and https://inpost.pl/polityka-prywatnosci).
Transfer of personal data – Sales system integration services
In the event of sales transactions using external tools for order management, customer service and sales data synchronization, some personal data of individuals or data of individuals conducting business activities may be transferred to entities providing sales system integration services to the Administrator. The transfer of this data takes place on the basis of a personal data processing entrustment agreement concluded between the Administrator and the given entity (more information can be found here: https://baselinker.com/pl-PL/polityka/ and www.ceneo.pl)
Transfer of personal data – Accounting services and issuing sales documents
In order to issue sales documents and keep accounting records, personal data of individuals or data of individuals conducting business activities may be transferred to entities providing accounting services to the Administrator and providing invoicing systems. The transfer of this data takes place on the basis of a personal data processing entrustment agreement concluded between the Administrator and the given entity (more information can be found here: https://fakturownia.pl/polityka-prywatnosci and https://fakturownia.pl/rodo).
Transfer of personal data – Newsletter and mailing campaign sending services
If the User expresses consent to receive commercial information electronically, personal data of natural persons or data of natural persons conducting business activity may be transferred to entities providing services to the Administrator in the scope of sending newsletters and conducting mailing campaigns. The transfer of this data takes place on the basis of a personal data processing entrustment agreement concluded between the Administrator and a given entity, only to the extent necessary to carry out information and marketing activities (more information can be found here: https://automattic.com/privacy/?utm_medium=automattic_referred&utm_source=mpcom_footer).
Transfer of personal data – Web analytics and marketing activities (Google)
If the User expresses prior consent to the processing of data for marketing and analytical purposes, some of the personal data of natural persons or the data of natural persons conducting business activities may be transferred to entities providing the Administrator with services in the field of web analytics, content personalization and online advertising activities (more information can be found here: https://policies.google.com/privacy and https://www.facebook.com/privacy/policy/?locale=pl_PL).
§7 Method of processing personal data
Personal data provided voluntarily by Users:
- Personal data will not be transferred outside the European Union, unless they have been published as a result of an individual action by the User (e.g. entering a comment or entry), which will make the data available to every person visiting the website.
- Personal data will not be used for automated decision-making (profiling).
- Personal data will not be resold to third parties.
Anonymous data (without personal data) collected automatically:
- Anonymous data (without personal data) will not be transferred outside the European Union.
- Anonymous data (without personal data) will not be used for automated decision-making (profiling).
- Anonymous data (without personal data) will not be sold to third parties.
§8 Legal basis for the processing of personal data
The website collects and processes Users’ data based on:
- 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 data)
- art. 6 section 1 letter a
the data subject has consented to the processing of his or her personal data for one or more specific purposes - art. 6 section 1 letter b
processing is necessary for the performance of a contract to which the data subject is party or to take action at the request of the data subject before concluding the contract - art. 6 section 1 letter f
processing is necessary for the legitimate interests pursued by the administrator or a third party
- art. 6 section 1 letter a
- Act of 10 May 2018 on the protection of personal data (Journal of Laws 2018, item 1000)
- Act of July 16, 2004 Telecommunications Law (Journal of Laws 2004, No. 171, item 1800)
- Act of February 4, 1994 on copyright and related rights (Journal of Laws 1994, No. 24, item 83)
§9 Personal data processing period
Personal data provided voluntarily by Users:
As a rule, the indicated personal data are stored only for the period of provision of the Service on the Website by the Administrator. They are deleted or anonymized for no longer than is necessary for the purposes for which the data are processed.
An exception is a situation that requires securing legally justified purposes of further processing of this data by the Administrator. In such a situation, the Administrator will store the indicated data from the time the User requests their removal, no longer than for a period of 3 years in the event of a violation or suspected violation of the provisions of the website regulations by the User.
Anonymous data (without personal data) collected automatically:
Anonymous statistical data, which do not constitute personal data, are stored by the Administrator to maintain website statistics for an indefinite period.
§10 Users’ rights related to the GDPR
The website collects and processes Users’ data on the basis of the GDPR, including the law described in Art. 15-22 GDPR.
Below you will find a description of your rights:
Right to access data Art. 15 GDPR
At any time, you have the right to check which of your personal data we process and find out:
- what is their scope;
- for what purposes they are processed;
- based on what legal bases we process them;
- who we share it with;
- what is the planned storage time.
If you want, you can receive a copy of your data from us – please contact us.
Right to rectification of data Art. 16 GDPR
You have the right to correct or supplement your personal data if it is incomplete or incorrect. If you have an account in the sarugami.pl store, you can correct or supplement your personal data at any time in the settings. You can also contact us to do this.
The right to delete data (right to be forgotten) Art. 17 GDPR
You have the right to delete your personal data that we process at any time (be forgotten). To do this, use a special button that is available when you log in to your account or contact us in another way convenient for you.
The exceptions are situations when:
- you have an open order – not yet shipped or only partially shipped,
- we are waiting for your payment, regardless of payment method,
- you are a person who has made purchases in our store – then we will keep your personal data regarding the transaction for reporting and accounting purposes, including evidentiary purposes,
- if a product purchased from us is subject to a temporary sales restriction, e.g. in terms of quantity, because it is difficult to obtain on the market – then we will not be able to delete your data until we remove the restrictions (we store the data necessary to determine whether you have already purchased a product subject to the restriction from us),
- if we are obliged to secure your data based on a request sent to us by an authorized state authority, e.g. the police, prosecutor’s office, court, etc.,
- if your data is necessary to establish, pursue, or defend against claims.
The right to limit processing Art. 18 GDPR
You can request that we restrict the processing of your personal data when:
- you do not consent to us processing your data on the basis of the legitimate interest of the administrator. We will restrict data processing if we determine that your rights override our legitimate interests,
- you report that your personal data is incorrect. We will limit the processing of your data until we have verified its accuracy,
- data processing is unlawful. You can then refuse to have your personal data deleted and instead request the restriction of the use of your personal data,
- we no longer need your personal data, but you need it to establish, pursue, or defend claims.
To exercise this right, please contact us.
Obligation to notify about rectification or deletion of data or restriction of processing Art. 19 GDPR
If you request it, we will inform you who is the recipient of your personal data.
We are obliged to inform everyone to whom we have transferred the data about rectification, deletion, or limitation of data processing if it is possible or does not require a disproportionate effort.
[legal basis: art. 16,17 or 18 GDPR]
Right to transfer data Art. 20 GDPR
You can exercise the right to transfer when, based on your consent or a contract concluded with you, we process your personal data in an automated manner. You have the right to receive a copy of your data from us in a structured, commonly used, and readable format.
We can send this copy directly to you or to another entity that will then process this data. Please note that this only applies to personal data that we have from you. If you would like to receive a copy of your data, please contact us.
Right to object Art. 21 GDPR
You have the right to object to the processing of your data to the extent that we do it on the basis of the legitimate interest of the administrator. You should justify such an objection. If you object, we will stop processing your personal data until we determine whether your rights override our interests.
We will not stop processing your data if your interest or rights are legally invalidated or if there are legal claims against you. In such a situation, we will inform you about it.
You do not have to justify your objection if it concerns the processing of data for direct marketing purposes, including profiling.
The right not to be subject to automated processing, including profiling, Art. 22 GDPR
You have the right not to consent to automated decision-making regarding your personal data, including profiling, which produces legal effects regarding you or similarly significantly affects you. You can withdraw your consent yourself if you have an account in our store – in the “Settings” tab. If you do not have an account, please contact us and report your withdrawal of consent.
To effectively exercise your right to object to the profiling of your personal data, you must log out from all devices and delete all cookies, including browsers (the deletion process may take up to 48 hours). You can learn how to properly delete cookies in the cookie policy.
The right to lodge a complaint with the supervisory authority, Art. 77 GDPR
If you believe that we are processing your personal data incorrectly, you have the right to submit a complaint to the supervisory authority, i.e. the Office for Personal Data Protection based in Warsaw at ul. Warsaw at Stawki Sr. Apt. 2, 00-193 Warszawa, details can be found on the website office.
You can always contact us if you think that we are processing your personal data incorrectly.
The right to refuse and withdraw consent at any time
If data processing requires your consent, you have the right not to express it. Such situations occur when, for example, we ask you if you want to receive marketing information from us.
You always have the right to withdraw your consent at any time, which you have expressed pursuant to Art. 7 section 3 GDPR, e.g. for marketing activities, and profiling, but remember that withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent expressed before its withdrawal.
§11 Contact the Administrator
You can contact the Administrator in one of the following ways
Postal address: AllTech Interactive Sp. z o. o., Wyścigowa St. Apt. 56E, 53-012 Wrocław
E-mail address: [email protected]
Telefon: +48 691 500 178
§12 Website Requirements
Restricting the storage and access to cookies on the User’s Device may result in incorrect operation of some functions of the Website.
The Administrator is not liable for incorrectly functioning functions of the Website if the User limits in any way the ability to save and read Cookie files.
§13 External links
The Website – articles, posts, entries, or comments by Users – may contain links to external websites with which the Website Owner does not cooperate. These links and the pages or files indicated under them may be dangerous to your Device or pose a threat to the security of your data. The Administrator is not responsible for the content located outside the Website.
§14 Changes to the Privacy Policy
The Administrator reserves the right to make any changes to this Privacy Policy without the need to inform Users regarding the use and use of anonymous data or the use of cookies.
The Administrator reserves the right to make any changes to this Privacy Policy regarding the processing of Personal Data, about which it will inform Users who have user accounts or are subscribed to the newsletter service via e-mail within 7 days of changing the records. Further use of the services constitutes reading and acceptance of the changes introduced to the Privacy Policy. Further use of the services constitutes reading and acceptance of the changes introduced to the Privacy Policy. If the User does not agree with the changes introduced, he or she is obliged to delete his or her account from the Website or/and unsubscribe from the Newsletter service.
Changes introduced in the Privacy Policy will be published on this subpage of the Website.
The changes introduced come into force upon publication.
