Privacy Policy
The following Privacy Policy defines the rules for storing and accessing data on Users' Devices used by the Website for the purpose of providing electronic services by the Administrator, and the rules for collecting and processing Users' personal data, which they have provided personally and voluntarily through the tools available on the Website.
The following Privacy Policy is an integral part of the Website Regulations, which defines the rules, rights, and obligations of Users using the Website.
§1 Definitions
Website - the "GAPA Store" website operating at https://sklep.gapa.com.pl/
External Service - websites of partners, service providers, or clients cooperating with the Administrator
Website / Data Administrator - The Administrator of the Website and the Data Administrator (hereinafter referred to as the Administrator) is the company "GAPA Organic. Karolina Grabowska", operating at: ul. Obwodowa 29B/U3, 84-240 Reda, with Tax Identification Number (NIP): 7732316290, providing electronic services through the Website
User - a natural person for whom the Administrator provides electronic services through the Website.
Device - an electronic device with software, through which the User accesses the Website
Cookies - text data collected in the form of files placed on the User's Device
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 (General Data Protection Regulation)
Personal Data - means any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who 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 to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
Restriction of processing - means the marking of stored personal data with the aim of limiting their processing in the future
Profiling - means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements
Consent - consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her
Personal data breach - means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed
Pseudonymisation - means the processing of personal data in such a manner that the personal data 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 the personal data are not attributed to an identified or identifiable natural person
Anonymisation - Anonymisation of data is an irreversible process of data operations that destroys / overwrites "personal data" making it impossible to identify or link a given record to a specific user or natural person.
§2 Data Protection Officer
Pursuant to Art. 37 of the GDPR, the Administrator has not appointed a Data Protection Officer.
For matters concerning data processing, including personal data, please contact the Administrator directly.
§3 Types of Cookies
Internal Cookies - files placed and read from the User's Device by the Website's ICT system
External Cookies - files placed and read from the User's Device by the ICT systems of External Services. Scripts of External Services that may place Cookies on Users' Devices have been consciously placed on the Website through scripts and services made available and installed on the Website.
Session Cookies - files placed and read from the User's Device by the Website during a single session of a given Device. After the session ends, the files are deleted from the User's Device.
Persistent Cookies - files placed and read from the User's Device by the Website until they are manually deleted. The files are not automatically deleted after the Device session ends unless the User's Device configuration is set to delete Cookie files after the Device session ends.
§4 Data Storage Security
Cookie Storage and Reading Mechanisms - Mechanisms for storing, reading, and exchanging data between Cookies saved on the User's Device and the Website are implemented through built-in web browser mechanisms and do not allow for downloading other data from the User's Device or data from other websites visited by the User, including personal data or confidential information. Transferring viruses, Trojan horses, and other worms to the User's Device is also practically impossible.
Internal Cookies - the Cookies used by the Administrator are safe for Users' Devices and do not contain scripts, content, or information that could endanger the security of personal data or the security of the Device used by the User.
External Cookies - The Administrator takes all possible actions to verify and select website partners in the context of User security. The Administrator selects well-known, large partners with global public trust for cooperation. However, the Administrator does not have full control over the content of Cookies originating from external partners. The Administrator is not responsible for the security of Cookie files, their content, and their licensed use by Scripts installed on the website, originating from External Services, to the extent permitted by law. A list of partners is provided later in the Privacy Policy.
Cookie Control
The User can, at any time, independently change the settings regarding the saving, deletion, and access to data stored in Cookie files by any website.
Information on how to disable Cookies in the most popular computer browsers is available on the page: how to disable cookies or from one of the indicated providers:
The User can, at any time, delete all previously saved Cookie files using the tools of the User's Device through which the User uses the Website's services.
User-side threats - The Administrator employs all possible technical measures to ensure the security of data placed in Cookie files. 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 its deletion, as a result of conscious or unconscious User activity, viruses, Trojan horses, and other spyware with which the User's Device may be or has been infected. To protect themselves from these threats, Users should adhere to internet usage rules.
Storage of personal data - The Administrator ensures that all efforts are made to keep personal data voluntarily provided by Users secure, with restricted access, and processed in accordance with their purpose and processing goals. The Administrator also ensures that all efforts are made to protect the data held against loss, by applying appropriate physical and organizational safeguards.
Password Storage - The Administrator declares that passwords are stored in encrypted form, using the latest standards and guidelines in this regard. Decryption of account access passwords provided on the Website is practically impossible.
§5 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 in external services
- Ad serving services
- Affiliate services
- Conducting statistics (users, number of visits, device types, connection, etc.)
- Serving multimedia services
- Providing social services
§6 Purposes of personal data processing
Personal data voluntarily provided by Users are processed for one of the following purposes:
- Provision of electronic services:
- User account registration and maintenance services on the Website and related functionalities
- Newsletter services (including sending promotional content with consent)
- Commenting / liking posts on the Website without the need for registration
- Services for sharing information about content placed on the Website on social media or other websites.
- Communication between the Administrator and Users regarding the Website and data protection
- Ensuring the legitimate interest of the Administrator
User data collected anonymously and automatically are processed for one of the following purposes:
- Conducting statistics
- Remarketing
- Serving advertisements tailored to User preferences
- Supporting affiliate programs
- Ensuring the legitimate interest of the Administrator
§7 External Service Cookies
The Administrator uses JavaScript scripts and web components from partners on the Website, who may place their own cookies on the User's Device. Remember that in your browser settings, you can decide which cookies are allowed to be used by individual websites. Below is a list of partners or their services implemented on the Website that may place cookies:
- Multimedia services:
- Social / integrated services:
(Registration, Login, content sharing, communication, etc.) - Newsletter services:
- Ad serving services and affiliate networks:
- Conducting statistics:
Services provided by third parties are beyond the Administrator's control. These entities may change their terms of service, privacy policies, data processing purposes, and methods of using cookies at any time.
§8 Types of data collected
The Website collects data about Users. Some data is collected automatically and anonymously, while some data is personal data voluntarily provided by Users when subscribing to individual services offered by the Website.
Anonymous data collected automatically:
- IP address
- Browser type
- Screen resolution
- Approximate location
- Subpages visited on the website
- Time spent on the respective subpage of the website
- Operating system type
- Previous subpage address
- Referrer page address
- Browser language
- Internet connection speed
- Internet service provider
Data collected during registration:
- First name / last name / nickname
- Login
- Email address
- IP address (collected automatically)
Data collected when subscribing to the Newsletter service
- First name / last name / nickname
- Email address
- IP address (collected automatically)
Data collected when adding a comment
- First and last name / nickname
- Email address
- Website address
- IP address (collected automatically)
Some data (without identifying data) may be stored in cookies. Some data (without identifying data) may be transferred to a statistical service provider.
§9 Access to personal data by third parties
As a rule, the sole 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 (most often based on a Data Processing Agreement) may be held by entities responsible for maintaining the infrastructure and services necessary to operate the website, i.e.:
- Hosting companies providing hosting or related services for the Administrator
- Companies through which the Newsletter service is provided
- Companies mediating online payments for goods or services offered within the Website (in case of making purchase transactions on the Website)
Entrustment of personal data processing - Newsletter
To provide the Newsletter service, the Administrator uses the services of a third party - the MailChimp, service. Data entered in the newsletter subscription form is transferred, stored, and processed on the external service of this provider.
Please be informed that the indicated partner may modify the specified privacy policy without the Administrator's consent.
Entrustment of personal data processing - Hosting, VPS, or Dedicated Server Services
To operate the website, the Administrator uses the services of an external hosting, VPS, or Dedicated Server provider -
Data processing in case of online payments
In the case of online payments, all payment-related data is transferred directly by the User to the payment processor -
§10 Method of personal data processing
Personal data voluntarily provided by Users:
- Personal data will not be transferred outside the European Union, unless it has been published as a result of an individual User action (e.g., adding a comment or post), which will make the data available to anyone 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 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 resold to third parties.
§11 Legal bases for personal data processing
The Website collects and processes User 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)
- Art. 6 para. 1 point (a)
the data subject has given consent to the processing of his or her personal data for one or more specific purposes - Art. 6 para. 1 point (b)
processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract - Art. 6 para. 1 point (f)
processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party
- Art. 6 para. 1 point (a)
- Act of May 10, 2018, on Personal Data Protection (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)
§12 Period of personal data processing
Personal data voluntarily provided by Users:
As a rule, the Administrator stores the specified personal data only for the period of Service provision within the Website. They are deleted or anonymized within 30 days from the end of service provision (e.g., deletion of a registered user account, unsubscribing from the Newsletter list, etc.)
An exception is a situation requiring the Administrator to secure legitimate interests for further processing of such data. In such a situation, the Administrator will store the indicated data, from the time of the User's request for their deletion, for no longer than 3 years in the event of a violation or suspected violation of the website's terms and conditions by the User.
Anonymous data (without personal data) collected automatically:
Anonymous statistical data, not constituting personal data, are stored by the Administrator indefinitely for the purpose of maintaining website statistics.
§13 User Rights related to personal data processing
The Website collects and processes User data based on:
Right of access to personal data
Users have the right to obtain access to their personal data, exercised upon a request submitted to the Administrator.Right to rectification of personal data
Users have the right to demand from the Administrator immediate rectification of personal data that are inaccurate or/and completion of incomplete personal data, exercised upon a request submitted to the Administrator.Right to erasure of personal data
Users have the right to demand from the Administrator immediate erasure of personal data, exercised upon a request submitted to the Administrator. In the case of user accounts, data deletion involves anonymization of data enabling User identification. The Administrator reserves the right to withhold the fulfillment of a data deletion request in order to protect the Administrator's legitimate interest (e.g., when the User has violated the Terms and Conditions or data was obtained as a result of ongoing correspondence).
In the case of the Newsletter service, the User has the option to independently delete their personal data by using the link placed in each sent email.Right to restriction of personal data processing
Users have the right to restrict the processing of personal data in cases indicated in Art. 18 of the GDPR, including questioning the accuracy of personal data, exercised upon a request submitted to the Administrator.Right to data portability
Users have the right to receive from the Administrator personal data concerning the User in a structured, commonly used and machine-readable format, exercised upon a request submitted to the Administrator.Right to object to personal data processing
Users have the right to object to the processing of their personal data in cases specified in Art. 21 of the GDPR, exercised upon a request submitted to the Administrator.Right to lodge a complaint
Users have the right to lodge a complaint with the supervisory authority dealing with personal data protection.
§14 Contacting the Administrator
You can contact the Administrator in one of the following ways:
Postal address - GAPA Organic. Karolina Grabowska, ul. Obwodowa 29B/U3, 84-240 Reda
Email address - karolina@gapa.com.pl
Phone number - 504 470 054
Contact form - available at: /kontakt
§15 Website Requirements
Restricting the storage and access to Cookie files on the User's Device may cause some Website functions to operate incorrectly.
The Administrator bears no responsibility for incorrectly operating Website functions if the User restricts in any way the ability to store and read Cookie files.
§16 External Links
On the Website - in articles, posts, entries, or User comments - there may be 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 for Your Device or pose a security threat to Your data. The Administrator is not responsible for content located outside the Website.
§17 Changes to the Privacy Policy
The Administrator reserves the right to make any changes to this Privacy Policy without the need to inform Users about it, regarding the use and utilization of anonymous data or the use of Cookie files.
The Administrator reserves the right to make any changes to this Privacy Policy regarding the processing of Personal Data, about which Users with user accounts or subscribed to the newsletter service will be informed via email within 7 days of the changes. Continued use of the services means familiarization with and acceptance of the introduced changes to the Privacy Policy. If the User does not agree with the introduced changes, they are obliged to delete their account from the Website or unsubscribe from the Newsletter service.
The introduced changes to the Privacy Policy will be published on this subpage of the Website.
The introduced changes come into effect upon their publication.