Privacy Policy of the Ministerstwo Dobrego Mydła shop
1. GENERAL INFORMATION
- This Privacy Policy (the "Policy"), together with the Shop's Cookie Policy, forms an integral part of the Terms and Conditions of the online shop operated by Bielun & Bielun sp. z o.o. at www.ministerstwodobregomydla.pl (the "Shop") and describes how we process your personal data, with whom we share it and how we keep it secure.
2. WHO IS THE CONTROLLER OF YOUR PERSONAL DATA?
- The controller of your personal data is Bielun & Bielun sp. z o.o., with its registered office in Szczecin, ul. Sosnowa 6c, 71-468 Szczecin, entered in the Register of Entrepreneurs kept by the District Court Szczecin-Centrum in Szczecin, 13th Commercial Division, under KRS number 0000729322, holding NIP (tax identification number): 8513223904, REGON (statistical number): 369533555, with a share capital of PLN 34,500 partly covered by a contribution in kind, hereinafter in this Privacy Policy referred to as the "Controller".
3. HOW CAN YOU CONTACT THE CONTROLLER OF YOUR PERSONAL DATA?
- If you have any questions about the personal data processing rules we apply, please contact us at the following e-mail address: [email protected], or, for enquiries sent by traditional post, please send them to the Controller's registered office (Bielun & Bielun sp. z o.o., ul. Sosnowa 6c, 71-468 Szczecin) marked "Dane osobowe IOD" (Personal data - DPO).
- We will forward your enquiries to our Data Protection Officer: Ms Urszula Ośmiałowska (e-mail: [email protected]).
4. SCOPE OF THE PERSONAL DATA PROCESSED, PURPOSE AND LEGAL BASIS OF PROCESSING
- The Controller processes the personal data of the Shop's users and customers within the scope, for the purposes and on the legal bases listed below. As a rule, the Controller may combine data obtained as a result of your various interactions with the Shop, depending on their intensity, the communication channels used and your wishes / enquiries. For example, if you have decided to create a customer account on the Shop's website, then in addition to the data in item 1 of the Table (Users visiting the website) we will naturally combine your data with the data in item 6 of the Table (Registered users of the Shop) or with complaint-related enquiries, etc. in order to make customer service easier.
- In addition, if the information provided during a call to the Helpline or via the contact form indicates that you are or have been a customer or a representative of one of our customers, the Controller may, at your request, combine the personal data you have provided with your history of purchases, promotional campaigns or complaints submitted to us. We may also combine your data with information concerning the safety and effectiveness of the products distributed by the Controller.
| Categories of data and persons | Scope of data | Purpose and legal basis for processing your data (Art. 6(1) GDPR, according to the letters indicated below) or under other provisions of generally applicable law |
|---|---|---|
| 1. Users visiting the Shop's website |
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Legal basis: Art. 6(1) GDPR, in particular points (a) and (f). As a rule, we will consider browsing the Shop's website as consent to the processing of the data indicated in item 1 of the Table. The processing of your data to this extent is necessary for the purposes of the legitimate interests pursued by the Controller, e.g. for archiving and statistical purposes, marketing, improving, updating and securing the website, as well as ensuring the compatibility of users' operating systems with our systems and your convenience. The Shop's Cookie Policy is set out in a separate document, but the Shop's website may contain embedded infrastructure elements provided by third-party suppliers such as Trustisto, Google Analytics, Facebook Pixel, Google Ads, Awin. These tools are used for analysis, sales segmentation and promotion. The Controller uses the above technologies to monitor actions taken by users on the Shop's website for the purposes of security and analysis, which may also be used in building promotional, mailing, push or other online campaigns. |
| 2. Persons who have consented to receive the newsletter |
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Legal basis: Art. 6(1) GDPR, in particular points (a) and (f). We may send you our newsletter for informational, marketing and promotional purposes if you have consented to this. |
| 3. Persons taking part in competitions / promotional campaigns |
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Legal basis: Art. 6(1) GDPR, in particular points (a) and (b), (c) and (f). If you take part in our competition, we will consider that you have consented to the processing of your personal data for this purpose. Our competitions usually take the form of a public promise or a promotional campaign offering you benefits, which is why the processing of data in such a situation is necessary for the performance of a contract to which you are a party or in order to take steps at your request. The processing of your data is necessary for compliance with a legal obligation to which the Controller is subject (with regard to tax, in particular if you receive a prize). The processing is necessary for the purposes of the legitimate interests pursued by the Controller, which may include, e.g. promoting the Shop and our products, but also organising competitions, including the collection of prizes, efficiently and safely for all participants. |
| 4. Users submitting general or product enquiries |
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Legal basis: Art. 6(1) GDPR, in particular points (a) and (b), (c), (d) and (f). The processing is necessary in order to take steps at your request prior to the possible conclusion of a contract (even if you decide not to conclude it). The processing is necessary in order to protect your vital interests or those of another natural person, e.g. enquiries concerning product properties, their potential allergens, etc. The processing is necessary for compliance with a legal obligation to which the Controller is subject or for the purposes of its legitimate interests, such as communicating any mandatory warnings about the products sold and their properties. |
| 5. Helpline users |
And where an order is placed or another instruction is given, also:
*In addition, if during a call to the Helpline you ask us to make changes to your user account or to the data we process on the Shop's website (e.g. to add extra discount points to your user profile, etc.) or to record a transaction in your purchase history, we may also process the following data of yours:
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Legal basis: Art. 6(1) GDPR, in particular points (a) and (b), (c) and (f). The processing of data is necessary for the performance of a sales contract to which you will be a party, or in order to take other steps at your request prior to entering into a contract, or to respond to any enquiry. The processing is necessary for compliance with a legal obligation to which the Controller is subject, e.g. issuing a receipt (if you decide to place an order). The processing is necessary for the purposes of the legitimate interests pursued by the Controller, such as providing any helpful information about the products sold and their properties, but also promoting its goods and services. We may add, e.g. a discount voucher to your parcel; if you do not indicate otherwise during the call, we will consider that you have consented to this. However, unregistered users cannot collect points in loyalty programmes and may only receive one-off vouchers or coupons that cannot be combined with other discounts. We do not record Helpline calls and, as a rule, we do not combine them with data obtained via the Shop's website, but we may do so, e.g. if you do not ask us not to. |
| 6. Registered users of the Shop |
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Legal basis: Art. 6(1) GDPR, in particular points (a) and (b), (c) and (f). If you create an account in our Shop, we will consider that you have consented to the processing of the data indicated for the purpose of convenient service and shopping, access to your purchase history and other conveniences that having an account in the Shop provides. The processing of such data is necessary for the performance of a sales contract to which you are a party, but also to enable you to use the full functionality of the account and the Shop, or in order to take steps at your request, e.g. choosing a courier and quickly dispatching goods, or redeeming discounts granted. The processing is necessary for compliance with a legal obligation to which the Controller is subject, in particular with regard to tax and consumer protection in online shopping. With regard to product opinions left on the Shop's website, the processing concerns personal data manifestly made public by you. The processing is necessary for the purposes of the legitimate interests pursued by the Controller (e.g. sending you promotional vouchers) or by a third party (e.g. IT service providers who supply us with various IT solutions so that you can conveniently use the extended features of the Shop). The processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party, consisting, e.g. of the analysis and combination of data by the Controller in order to enable you to use all the functionality and conveniences of the account, including building and storing its history, saving purchasing and analytical profiles, e.g. consisting of combining data into an organised whole in order to grant you a discount, saving your purchase history to which you can easily return in order to repeat purchases, and facilitating the return of goods or complaints about them. We may also use this data to improve the quality of our services, to better tailor our offer to your needs and to analyse the performance of the Shop's website. |
| 7. Unregistered users of the Shop (without a customer account) |
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Legal basis: Art. 6(1) GDPR, in particular points (a) and (b), (c) and (f). a) Even if you do not create an account in our Shop, we will consider that you have consented to the processing of the data indicated for the purpose of making purchases or submitting enquiries, complaints, etc. concerning them. b) The processing of such data is necessary for the performance of a contract to which you are a party, or in order to take steps at your request, e.g. choosing a courier and quickly dispatching goods. c) The processing is necessary for compliance with a legal obligation to which the Controller is subject, in particular with regard to tax and accounting and consumer protection in online shopping. f) The processing is necessary for the purposes of the legitimate interests pursued by the Controller (e.g. sending you promotional vouchers) or by a third party (e.g. IT service providers who supply us with various IT solutions so that you can conveniently use our Shop even without registering). |
| 8. Payment data (*if you have decided to make purchases in our Shop) |
*For payment methods other than bank transfer, our Shop does not receive data concerning your credit card number or account number (e.g. for Blik payments), and in particular does not receive transaction authentication data. |
Legal basis: Art. 6(1) GDPR, in particular points (a), (b) and (c), as well as Articles 106b and 111 of the Polish Act of 11 March 2004 on Goods and Services Tax and other relevant acts. The processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request with a view to concluding a sales contract. The processing is necessary for compliance with a legal obligation to which the Controller is subject, in particular with regard to accounting and tax. |
| 9. Persons reporting potential undesirable effects (*if such data has been provided by the reporting person) or persons affected by a possible recall of a cosmetic product |
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Legal basis: Art. 6(1) GDPR, in particular points (a), (c), (d) and (f), as well as Regulation (EC) No 1223/2009 of the European Parliament and of the Council and Art. 11 of the Polish Act of 4 October 2018 on Cosmetic Products and other relevant legal provisions. The processing of your data is necessary for the proper subsequent performance of a contract to which you are a party, in particular the exercise of consumer rights. The processing is necessary for compliance with a legal obligation to which the Controller is subject, e.g. with regard to monitoring possible undesirable effects. The processing is necessary in order to protect your vital interests, but also those of any other potential users of cosmetic products, and to provide you with appropriate information, including for the protection of life and health. The processing is necessary for the purposes of the legitimate interests pursued by the Controller, in particular improving product safety, the quality of services and the accuracy of the information provided about products and services, the Controller's scientific research and development, as well as for the defence of claims. |
5. HOW DO WE OBTAIN YOUR DATA?
- We obtain your data directly from you. We use it to the extent described above because you have visited our Shop's website, made purchases from us, contacted us by e-mail or telephone, consented to receive commercial information by electronic means or taken part in one of our competitions.
6. PROFILING AND AUTOMATED DECISION-MAKING
- The Controller may profile your data, including your purchase history and the data indicated in Section 4 of this Policy, in particular using the Trustisto tool and the tools described in the Cookie Policy.
- The Controller does not process your data for the purpose of automated decision-making.
- Your personal data concerning activity on the Shop's website may be profiled by third-party providers of technical solutions, in particular cookie providers, e.g. Google Ads, Google Maps, IAI S.A., Meta, Trustisto, in accordance with the privacy policies of these third-party providers and your cookie choices. The rules for the processing of data by the above third parties, which are not affiliated with the Controller, are set out in their separate privacy policies, which the User should read independently. If you do not consent to such processing, we encourage you to place orders via our Helpline or in person in our brick-and-mortar shops. A list of our brick-and-mortar shops can be found here.
7. IS PROVIDING PERSONAL DATA MANDATORY?
- It is up to you to decide whether and what data you share with us, depending on the form and purpose of your contact with us, as indicated in Section 4 of this Policy. However, refusing to provide certain data or limiting its scope may make it impossible to make purchases via the Shop's website or to use all of its functionality. In turn, refusing to provide a delivery address or payment data will require the order to be cancelled. If you do not consent to the processing of data described in this document, we encourage you to make purchases in our brick-and-mortar shops. A list of our brick-and-mortar shops can be found here.
8. WITH WHOM WILL WE SHARE YOUR PERSONAL DATA?
- Your personal data may be shared with authorised employees or associates of the Controller, as well as with external entities cooperating with the Controllers. This includes in particular providers of IT systems and services (e.g. Idosell, Presta); providers of technical and organisational solutions supporting the Controllers' operational activities (courier companies and payment operators); entities offering tools and services related to tax, accounting, financial planning and analysis, human resources, customer relations and supply chain management. Data may also be transferred to entities entitled to receive it under applicable law.
- All these entities will process your personal data in accordance with data processing agreements concluded with the Controller or in accordance with applicable data protection law. The entities listed above may include the following categories of recipients:
- Entities supporting the Controllers' operational activities, e.g. courier companies and payment operators, including entities from the Comarch group with regard to e-receipts and invoices.
- Public authorities, e.g. the Tax Office, the Chief Sanitary Inspector (GIS) or other state authorities, where required by law.
- Intermediaries and business partners of the Controller involved in business activities.
- External service providers, e.g. those providing marketing services to the Controllers.
- Legal, financial, tax and accounting advisers engaged to support the Controllers' regulatory compliance.
- The courier companies that work with us to provide the services necessary to deliver the goods you have purchased, depending on your choice, are:
- DHL eCommerce (Poland) Sp. z o.o.,
- DPD Polska Sp. z o.o.,
- FedEx Express Poland Sp. z o.o.,
- Inpost Spółka z ograniczoną odpowiedzialnością,
- other entities that may in future provide delivery services for goods you have purchased in the Shop.
- The payment companies that work with us to handle the payments necessary to perform the sales contract for the goods you have purchased, depending on your choice, are:
- for issuing e-receipts: entities from the Comarch group,
- the courier companies listed above, if you have chosen the "cash on delivery" payment method for the selected goods,
- PayU S.A.,
- PayPal (Europe) S.à r.l. et Cie, S.C.A.,
- PayPo Sp. z o.o.,
- ING Bank Śląski S.A., which handles the receipt of payments on our Shop's side,
- possibly other payment operators with whom we may begin to cooperate in order to receive payment for the goods you have purchased.
- Depending on the method of delivery of goods and payment you choose, we will share your data necessary for the performance of the contract and payment with the above entities indicated by you. However, the terms and conditions of these entities may contain provisions on the processing of your data that differ from this Policy.
- Analytical and marketing tools provided by third parties, in particular Google (e.g. Google Ads, Google Analytics) and Meta Platforms (e.g. Facebook Pixel), or Trustisto, may be used on the Shop's website. These tools may use cookies and other tracking technologies for the purpose of:
- analysing website traffic,
- conducting marketing activities,
- tailoring advertising content delivered by the above entities to the user's preferences.
The user can manage cookie settings and consents and give or withdraw consent to their use via their own browser settings or the cookie management tool.
If you accept all cookies, the use of these tools means that your data may be transferred to third countries (e.g. the USA), in accordance with the rules set by the providers of these services.
Outside the structure of the Shop's website, the controllers of data collected via cookies are primarily the external providers of these services, in accordance with their own terms and conditions and privacy policies.
The Controller of the Website has no control over how the above third parties process data with regard to its further use for their own marketing or analytical purposes. The rules for the processing of data by these entities are set out in their separate privacy policies, which you should read independently. Such processing can be limited by the user rejecting cookies or by making purchases via the Helpline or in our brick-and-mortar shops, a list of which is available here.
9. PROCESSING OF DATA OUTSIDE THE EEA
- The Controller does not export your data to third countries outside the European Economic Area (the "EEA"). However, external providers of technical solutions used on the Controller's website may make such transfers independently of the Controller. More information on this and on ways of limiting transfers by these entities can be found in Section 8 of this Policy.
10. HOW LONG WILL WE PROCESS YOUR PERSONAL DATA?
- Your personal data will be processed for the periods necessary to achieve the purposes set out in the Shop's Terms and Conditions, in particular the performance of the sales contract and consumer rights, including your complaint claims, as well as confirming the fulfilment of our obligations. We usually store data related to orders and sales in accordance with the archiving obligations set out in Polish law or in accordance with the statutory limitation periods for claims. Accordingly, your data will be processed for the duration of the provision of services and, after their completion, for the periods necessary to pursue the Controller's legitimate interests.
- As a rule, the Controller will apply the following data retention periods, depending on the nature of your interaction with our Shop and the type of data processed:
- Data concerning purchases by unregistered users: 2 years from the date of purchase.
- Data concerning purchases by registered users: 3 years from the date of purchase or from the date of the last account activity, or account closure.
- Data concerning complaints and returns, in particular product defects: 2 years from the end of the complaint process, and in the case of a return up to 6 years, if necessary.
- Data contained in accounting and financial documentation (e.g. invoices, receipts): 5 - 10 years from the end of the calendar year in which the sale/order was completed (in accordance with tax regulations and the nature of the purchases), or longer if required by specific regulations.
- Data contained in product opinions (especially those published on the website): for as long as the Shop's website exists, unless you request their earlier deletion.
- Data concerning possible undesirable effects of products - for a period of a maximum of 1 year from the date on which the process of verifying and analysing the report is completed.
- Marketing data (e.g. newsletters or e-mails): until you withdraw your consent, but no longer than 6 months to 1 year from the last contact.
- In exceptional cases, longer retention periods may apply. Where required by law, or where legal proceedings are pending or reasonably anticipated, personal data may be stored for a longer period. In addition, certain contracts, agreements or industry regulations may impose different data retention obligations which take precedence over the general retention periods, in particular regulations concerning cosmetic products.
11. WHAT RIGHTS DO YOU HAVE IN CONNECTION WITH THE PROCESSING OF YOUR DATA?
- You have a number of rights relating to the protection of your personal data under the GDPR. These include, among others:
- The right to access your data and to receive a copy of it in a format allowing it to be transferred.
- The right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
- The right to rectification (correction) or erasure of your personal data.
- The right to restriction of the processing of personal data.
- The right to erasure of personal data.
- The right to lodge a complaint with the President of the Personal Data Protection Office (UODO), ul. Stanisława Moniuszki 1A, 00-014 Warszawa, Poland (the supervisory authority competent for the Controller).
- If you submit any of the above requests, we will provide you with information/a response within the statutory time limit or inform you of its extension and explain the reasons. If we have any doubts as to the nature of your request, we may ask a few additional questions and ask you to verify your identity.
12. PROHIBITED ACTIVITIES
- The Controller prohibits visiting or using any part of the Shop's website, including contact forms, for the purpose of obtaining the personal data of other natural persons (data mining), in particular the personal data of the Shop's users or the Controller's employees and/or associates. Furthermore, the use of any data mining tools or similar tools to collect and extract any data from the Shop's website is prohibited.
- The Controller does not collect or process the personal data of children. If you are under 13 years of age, you may use the Shop's website only with the involvement of a parent or legal guardian, who will contact us on your behalf.
- Although we make every effort to ensure the security of the Shop's website, we cannot guarantee the security or confidentiality of information transmitted via the Internet. However, we will make every effort to maintain its confidentiality where personal data has been provided in good faith. For this reason, we ask you not to send information that you consider harmful, unlawful, confidential, sensitive or valuable ("undesirable content").
- Although we value users' opinions, we expect you to refrain from sending undesirable content. Accordingly, we accept no liability towards you or third parties for the confidentiality of such materials or their potential use. Content submitted by users, in particular via contact forms, must meet standards of accuracy, decency and lawfulness and may be used for the purposes described in this Policy. In particular, content submitted by you must:
- be your own original work and be submitted lawfully; in particular, it must not contain defamatory content or elements bearing the hallmarks of defamation of any person or entity;
- be consistent with the facts or reflect your genuine beliefs;
- comply with ethical standards and not contain offensive, obscene, sexual, discriminatory or misleading content, or content that is otherwise insulting, embarrassing or harassing.
- As a rule, the Shop's website is interactive and allows registered users to post comments / opinions publicly, but such content should not disclose the personal data of other users or third parties. If in future we decide to enable message boards or other communication services on the Shop's website, we will not be obliged to monitor or moderate such content or the personal data posted there. However, if we decide to monitor or moderate content, we will provide information about the moderation methods. At our sole discretion, we may remove or edit any materials or personal data posted on the Shop's website.
- We may delete any personal data provided to us (before the end of the retention periods set out in this Policy) if we have reasonable grounds to believe that it was provided in bad faith, infringes the rights of third parties (such as the right to privacy or image) or was intended to disrupt the services offered by the Shop or to breach the security of our IT systems, in particular where the Shop's website could be used:
- for purposes contrary to applicable law, principles of social coexistence or this Policy;
- to contact us with fraudulent, criminal or otherwise unlawful intent;
- to distribute viruses, malware or similar software, in particular in order to gain unauthorised access to computers, data, systems, accounts or networks;
- to promote unsolicited advertising, messages or spam;
- to impersonate us or other entities, or to obtain personal data, authentication data or other valuable information (e.g. "phishing", "smishing", "vishing");
- in a manner that disrupts the functioning of the Shop's website or the activities of the Controller, its affiliates or any third parties;
- in breach of intellectual property rights or software licensing rules.
13. FINAL PROVISIONS
- The Shop's website may contain hyperlinks or redirects to other websites or applications belonging to third parties. This does not mean that we endorse the security or privacy rules of such entities. These links are provided solely for your convenience. We have no control over third-party websites or applications and are not responsible for their content or for the way in which these entities process your personal data, and we accept no liability in this respect. Your use of third-party websites or applications is usually subject to different personal data processing rules set by those entities, which you should read independently.
- Any changes to this Privacy Policy take effect on the date of their publication on the Shop's website. However, we reserve the right to change this Policy at any time. By continuing to use the Shop's website or the Helpline, you accept these changes and undertake to comply with them. It is the user's responsibility to regularly read the provisions of this Policy and its updates. If you do not agree with the rules set out in this Policy, please leave the Shop's website immediately and refrain from using the Helpline and purchasing our products in our brick-and-mortar shops.