Privacy Policy
1. GENERAL PROVISIONS
1.1. This privacy policy of the Online Store is for informational purposes, which means it is not a source of obligations for Users or Clients of the Online Store. The privacy policy primarily contains rules regarding the processing of personal data by the Administrator in the Online Store, including the grounds, purposes, and scope of the processing of personal data as well as the rights of individuals whose data are being processed, and information on the use of cookies and analytical tools in the Online Store.
1.2. The Administrator of personal data collected via the Online Store is Sashweightslondon, maintained by the minister responsible for the economy, with the business address and address for service: 14 Gorst Road, London, NW10 6LE, e-mail address: contact@sashweightslondon.com , telephone number: 0203 318 2525, referred to as the “Administrator” and being both the service provider of the Online Store and the Seller.
1.3. Contact details of the data protection officer appointed by the Administrator: There is no appointed data protection officer – information to be completed by the Administrator.
1.4. Personal data in the Online Store are processed by the Administrator in accordance with the applicable laws, particularly in accordance with 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 (General Data Protection Regulation – "GDPR"). Official text of the GDPR: http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32016R0679.
1.5. The use of the Online Store, including making purchases, is voluntary. Similarly, providing personal data by the User or Client of the Online Store is voluntary, except for two cases: (1) concluding agreements with the Administrator – failure to provide the personal data necessary for the conclusion and performance of the Sale Agreement or the agreement for the provision of Electronic Services as indicated on the Online Store’s website and in the Online Store Regulations will result in the inability to conclude such an agreement. The provision of personal data is a contractual requirement, and if the person concerned wishes to conclude the agreement with the Administrator, they are required to provide the required data. The scope of data required for the conclusion of the agreement is indicated on the Online Store's website and in the Online Store Regulations; (2) statutory obligations of the Administrator – providing personal data is a statutory requirement resulting from generally applicable legal provisions that impose on the Administrator an obligation to process personal data (e.g., for the purpose of keeping tax or accounting records), and failure to provide them will prevent the Administrator from fulfilling these obligations.
1.6. The Administrator takes particular care to protect the interests of individuals whose personal data are processed, and in particular, is responsible for ensuring that the data collected are:
- (1) processed in accordance with the law;
- (2) collected for specified, lawful purposes and not further processed in a way incompatible with those purposes;
- (3) factually correct and adequate in relation to the purposes for which they are processed;
- (4) stored in a form that permits the identification of the data subjects for no longer than is necessary for the purposes for which the data are processed; and
- (5) processed in a way that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.
1.7. Taking into account the nature, scope, context, and purposes of the processing, as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, the Administrator implements appropriate technical and organizational measures to ensure that the processing is carried out in accordance with this regulation and to be able to demonstrate it. These measures are reviewed and updated as necessary. The Administrator applies technical measures to prevent unauthorized persons from obtaining and modifying personal data sent electronically.
1.8. All words, expressions, and acronyms used in this privacy policy and beginning with a capital letter (e.g., Seller, Online Store, Electronic Service) should be understood in accordance with their definitions contained in the Online Store Regulations available on the Online Store's website.
2. LEGAL BASIS FOR DATA PROCESSING
2.1. The Administrator is entitled to process personal data in cases where – and to the extent that – at least one of the following conditions is met:
- (1) the data subject has given consent to the processing of their personal data for one or more specific purposes;
- (2) processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject prior to entering into a contract;
- (3) processing is necessary for compliance with a legal obligation to which the Administrator is subject;
- (4) processing is necessary for the purposes of the legitimate interests pursued by the Administrator or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, especially where the data subject is a child.
2.2. The processing of personal data by the Administrator requires the presence of at least one of the legal grounds indicated in point 2.1 of this privacy policy. The specific grounds for processing personal data of Online Store Users and Clients by the Administrator are indicated in the next point of the privacy policy – in relation to the specific purpose of data processing by the Administrator.
3. PURPOSE, BASIS, AND PERIOD OF DATA PROCESSING IN THE ONLINE STORE
3.1. Each purpose, basis, and period of data processing by the Administrator depends on the actions taken by the User or Client in the Online Store. For example, if a Client decides to make a purchase in the Online Store and selects product delivery rather than personal collection, their personal data will be processed to conclude and perform the Sale Agreement, but will not be processed for marketing purposes if they have not given separate consent.
3.2. The Administrator may process personal data within the Online Store for the following purposes, on the following legal bases, and for the periods indicated in the table below:
| Purpose of data processing | Legal basis for data processing | Data retention period |
|---|---|---|
| Performance of the Sale Agreement or Electronic Service Agreement or taking actions at the request of the data subject prior to the conclusion of such agreements | Article 6(1)(b) of the GDPR (contract performance) – processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject prior to entering into a contract | Data are retained for the period necessary for the performance, termination, or expiration of the contract |
| Direct marketing | Article 6(1)(f) of the GDPR (legitimate interest of the administrator) – processing is necessary for the purposes of the legitimate interests pursued by the Administrator, which include protecting the interests and good reputation of the Administrator, the Online Store, and striving to sell Products | Data are retained for the period of the legitimate interest pursued by the Administrator, but no longer than the period of limitation of the Administrator's claims against the individual. The limitation period is determined by the provisions of law, in particular, the Civil Code (the basic limitation period for claims related to conducting business is three years, and for a sales contract, two years). The Administrator may not process data for direct marketing purposes if the data subject objects to it. |
| Marketing | Article 6(1)(a) of the GDPR (consent) – the data subject has given consent to the processing of their personal data for marketing purposes | Data are retained from the moment consent is given until the moment consent is withdrawn. |
| Providing opinions by the Client on the concluded Sale Agreement | Article 6(1)(a) of the GDPR – the data subject has given consent to the processing of their personal data for the purpose of expressing an opinion | Data are retained until the consent is withdrawn, but no longer than five years from the date of expressing the opinion. |
| Keeping tax or accounting records | Article 6(1)(c) of the GDPR in connection with Article 86 § 1 of the Tax Ordinance of 17 January 2017 (Journal of Laws 2017, item 201) or Article 74(2) of the Accounting Act of 30 January 2018 (Journal of Laws 2018, item 395) – processing is necessary for compliance with a legal obligation to which the Administrator is subject | Data are retained for the period required by law, which requires the Administrator to store tax or accounting records (5 years, starting from the beginning of the year following the financial year to which the data pertain). |
| Establishing, pursuing, or defending claims that may be raised by the Administrator or that may be raised against the Administrator | Article 6(1)(f) of the GDPR (legitimate interest of the administrator) – processing is necessary for the purposes of the legitimate interests pursued by the Administrator | Data are retained for the period of the legitimate interest pursued by the Administrator, but no longer than the limitation period for claims in relation to the individual (the basic limitation period for claims is six years, and for business-related claims, three years). |
| Using the Online Store and ensuring its proper functioning | Article 6(1)(f) of the GDPR (legitimate interest of the administrator) – processing is necessary for the purposes of the legitimate interests pursued by the Administrator, which include operating and maintaining the Online Store | Data are retained for the period of the legitimate interest pursued by the Administrator, but no longer than the limitation period for the Administrator's claims against the individual. The limitation period is determined by the provisions of law, in particular, the Civil Code (the basic limitation period for claims is three years, and for a sales contract, two years). |
| Conducting statistics and analyzing traffic in the Online Store | Article 6(1)(f) of the GDPR (legitimate interest of the administrator) – processing is necessary for the purposes of the legitimate interests pursued by the Administrator, which include conducting statistics and analyzing traffic in the Online Store to improve the functionality of the Online Store and increase sales of Products | Data are retained for the period of the legitimate interest pursued by the Administrator, but no longer than the limitation period for claims. The limitation period is determined by the provisions of law, in particular, the Civil Code (the basic limitation period for claims is three years, and for a sales contract, two years). |
4. RECIPIENTS OF DATA IN THE ONLINE STORE
4.1. For the proper functioning of the Online Store, including the performance of Sale Agreements, it is necessary for the Administrator to use the services of external entities (such as software providers, couriers, or payment processors). The Administrator uses only the services of processors that provide sufficient guarantees of implementing appropriate technical and organizational measures so that the processing meets the requirements of the GDPR and protects the rights of individuals whose data are being processed.
4.2. The transfer of data by the Administrator does not take place in every case and not to all recipients or categories of recipients indicated in the privacy policy – the Administrator transfers data only when it is necessary to achieve the given purpose of processing personal data and only to the extent necessary to achieve it. For example, if a Client uses personal collection, their data will not be transferred to the courier cooperating with the Administrator.
4.3. The personal data of Users and Clients of the Online Store may be transferred to the following recipients or categories of recipients:
- 4.3.1. couriers / freight forwarders / shipping brokers / entities handling warehousing and/or shipping processes – in the case of a Client who uses delivery via post and/or courier, the Administrator transfers the personal data collected from the Client to the selected carrier, freight forwarder, or intermediary performing the shipment on behalf of the Administrator, or if the shipment is made from an external warehouse – to the entity operating the warehouse and/or shipping process, in the necessary scope to carry out the delivery of the Product to the Client;
- 4.3.2. entities processing electronic payments or card payments – in the case of a Client who uses electronic payment or card payment in the Online Store, the Administrator transfers the personal data of the Client to the selected entity handling the above payments on behalf of the Administrator, to the extent necessary to process the payment made by the Client;
- 4.3.3. lenders / leasing providers – in the case of a Client who uses installment payments or leasing payments in the Online Store, the Administrator transfers the personal data of the Client to the selected lender or leasing provider handling the above payments on behalf of the Administrator, to the extent necessary to process the payment made by the Client;
- 4.3.4. providers of opinion polling systems – in the case of a Client who agrees to provide an opinion on the concluded Sale Agreement in the Online Store, the Administrator transfers the personal data of the Client to the selected entity providing opinion polling systems in the Online Store on behalf of the Administrator, to the extent necessary to operate the opinion polling system;
- 4.3.5. providers supplying the Administrator with technical, IT, and organizational solutions that enable the Administrator to conduct business, including the Online Store and the services provided through it (in particular, software providers for operating the Online Store, email, and hosting providers, and software providers for managing the company and providing technical support to the Administrator) – the Administrator transfers the personal data of the Client to the selected provider acting on behalf of the Administrator only in cases and to the extent necessary to achieve the specific purpose of data processing that is consistent with this privacy policy;
- 4.3.6. accounting, legal, and advisory service providers supporting the Administrator with accounting, legal, or advisory services (in particular, accounting firms, law firms, or debt collection companies) – the Administrator transfers the personal data of the Client to the selected provider acting on behalf of the Administrator only in cases and to the extent necessary to achieve the specific purpose of data processing that is consistent with this privacy policy;
- 4.3.7. providers embedded in the Online Store through social plugins, scripts, and other similar tools that allow visitors to view the Online Store using social media plugins (e.g., logging in via social media credentials) and transfer personal data to these providers of the visitors to the Online Store, including:
- Meta Platforms Ireland Ltd. – The Administrator uses social media plugins from Facebook on the Online Store’s website (e.g., "Like" button, "Share" button) and logging in via Facebook, and in this connection collects and shares the personal data of Users with Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, in accordance with the privacy policies available here: https://www.facebook.com/about/privacy/ (this data includes information about devices, visited websites, purchases, viewed ads, and how services are used, linked to logging into Facebook accounts and whether the user is logged in to Facebook).
5. PROFILING IN THE ONLINE STORE
5.1. The GDPR imposes an obligation on the Administrator to inform about automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR, and – at least in those cases – important information about the rules for making such decisions as well as the significance and anticipated consequences of such processing for the data subject. In light of this, the Administrator provides information on the possible profiling in this section of the privacy policy.
5.2. The Administrator may use profiling in the Online Store for direct marketing purposes, but decisions made on the basis of this by the Administrator do not concern the conclusion or refusal to conclude a Sale Agreement, or the possibility of using Electronic Services in the Online Store. The result of profiling in the Online Store may include, for example, granting a discount to a person, sending them a discount code, reminding them of unfinished purchases, sending them product proposals that may match their interests or preferences, or offering better terms compared to the standard offer of the Online Store. Despite profiling, the person makes a free decision whether they want to use the discount received in this way or the better terms and make a purchase in the Online Store.
5.3. Profiling in the Online Store consists of the automatic analysis or prediction of a person’s behavior on the Online Store's website, e.g., by adding a specific Product to the shopping cart, browsing a specific Product’s page in the Online Store, or by analyzing their purchase history in the Online Store. The condition for such profiling is the possession by the Administrator of the personal data of the person to whom the Administrator can later send, for example, a discount code.
5.4. The person whose data is being processed has the right not to be subject to a decision that is based solely on automated processing, including profiling, and that produces legal effects concerning them or similarly significantly affects them.
6. RIGHTS OF THE DATA SUBJECT
6.1. Right of access, rectification, restriction, erasure, or data portability – the data subject has the right to request access to their personal data from the Administrator, to rectify, erase ("right to be forgotten") or restrict the processing of their data, and has the right to object to the processing, as well as the right to data portability. Detailed conditions for exercising the above rights are set out in Articles 15-21 of the GDPR.
6.2. Right to withdraw consent at any time – the person whose data is processed by the Administrator on the basis of expressed consent (under Article 6(1)(a) or Article 9(2)(a) of the GDPR) has the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
6.3. Right to lodge a complaint with a supervisory authority – the person whose data is processed by the Administrator has the right to lodge a complaint with a supervisory authority in the manner and according to the procedures set out in the GDPR and Polish law, in particular, the Personal Data Protection Act. The supervisory authority in Poland is the President of the Personal Data Protection Office.
6.4. Right to object – the person whose data is processed has the right to object at any time – for reasons related to their particular situation – to the processing of their personal data based on Article 6(1)(e) (public interest) or (f) (legitimate interest of the Administrator), including profiling based on these provisions. In such cases, the Administrator may no longer process the personal data unless it demonstrates compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the data subject, or for the establishment, exercise, or defense of legal claims.
6.5. Right to object to direct marketing – if personal data are processed for direct marketing purposes, the person whose data is being processed has the right to object at any time to the processing of their personal data for such marketing purposes, including profiling to the extent that it is related to such direct marketing.
6.6. The right to exercise rights, as referred to in this privacy policy, may be contacted by the Administrator, for example, by sending an appropriate message in writing or by email to the Administrator’s address indicated at the beginning of the privacy policy, or by using the contact form available on the Online Store's website.
7. COOKIES IN THE ONLINE STORE AND ANALYTICS
7.1. Cookies are small pieces of information in the form of text files sent by a server and stored on the side of the person visiting the Online Store (e.g., on the hard drive of a computer, laptop, or on a smartphone’s memory card – depending on the device used by the visitor to the Online Store). Detailed information on Cookies and the history of their creation can be found here: https://en.wikipedia.org/wiki/HTTP_cookie.
7.2. Cookies that may be sent by the Online Store’s website can be divided into different types, based on the following criteria:
| According to their provider: | According to their retention period on the device of the Online Store visitor: | According to their purpose: |
|---|---|---|
| 1) own (created by the Online Store’s website) and 2) belonging to third parties (other than the Administrator) | 1) session cookies (stored until logging out of the Online Store or closing the web browser) 2) persistent cookies (stored for a specified time, defined by the parameters of each file or until manually deleted) | 1) necessary (allowing the proper functioning of the Online Store), 2) functional/preferential (allowing the Online Store to be adapted to the preferences of the person visiting), 3) analytical and performance (collecting information on how the Online Store is used), 4) marketing, advertising, and social (collecting information about the visitor to the Online Store in order to display ads and other information tailored to their interests on and off the Online Store, including on third-party websites such as social media). |
7.3. The Administrator may process the data contained in cookies during the use of the Online Store by visitors for the following specific purposes:
| Purposes of using cookies in the Online Store |
|---|
| Identifying Users as logged in to the Online Store and showing that they are logged in (necessary cookies) |
| Remembering Products added to the shopping cart for placing an order (necessary cookies) |
| Remembering data from completed Order Forms, surveys, or login data to the Online Store (necessary and/or functional/preferential cookies) |
| Adapting the content of the Online Store to individual preferences of the User (e.g., regarding colors, font size, layout) and optimizing the use of the Online Store (functional/preferential cookies) |
| Conducting anonymous statistics showing how the Online Store is used (statistical cookies) |
| Remarketing, i.e., examining the behavior of Online Store visitors through anonymous analysis of their activities (e.g., recurring visits to certain pages, keywords, etc.) to create their profile and deliver ads tailored to their presumed interests, even when they visit other websites in the advertising network of Google Ireland Ltd. and Facebook, i.e., Meta Platforms Ireland Ltd. (marketing, advertising, and social cookies) |
7.4. Checking in popular web browsers which cookies (including their functioning period and provider) are currently sent by the Online Store’s website is possible in the following ways:
| In Chrome: | In Firefox: | In Internet Explorer: |
|---|---|---|
| (1) in the address bar, click the lock icon on the left side, (2) go to the “Cookies” tab | (1) in the address bar, click the shield icon on the left side, (2) go to the “Allowed” tab, (3) click “Blocked,” (4) select “Cross-site tracking cookies,” “Social media trackers,” or “Content trackers” | (1) click the “Tools” menu, (2) go to “Internet options,” (3) click “General,” (4) go to the “Settings” tab, (5) click “View files” |
| In Opera: | In Safari: | In Microsoft Edge: |
|---|---|---|
| (1) in the address bar, click the lock icon on the left side, (2) go to the “Cookies” tab | (1) click the “Preferences” menu, (2) click the “Privacy” option, (3) go to the “Manage website data” tab | Regardless of the browser, using tools available at: https://www.cookiemetrix.com or https://www.cookie-checker.com |
7.5. By default, most web browsers available on the market accept saving cookies by default. Everyone has the option to define the conditions for using cookies via their browser settings. This means that you can, for example, partially restrict (e.g., temporarily) or completely disable the possibility of saving cookies – in the latter case, however, it may affect some functionalities of the Online Store (for example, it may not be possible to store products in the Shopping Cart during the next steps of placing an order).
7.6. The settings of the web browser for cookies are important from the point of view of consent to the use of cookies by our Online Store – in accordance with the regulations, such consent can also be expressed through the browser settings. Detailed information on how to change cookie settings and delete cookies on your own in the most popular web browsers can be found in the browser’s help section and on the following pages (just click on the appropriate link):
7.7. The Administrator may use Google Analytics and Universal Analytics services provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) in the Online Store. These services help the Administrator conduct statistics and analyze traffic in the Online Store. The collected data are processed as part of these services in an anonymized manner (these are so-called operational data, which prevent the identification of a person). The Administrator uses these services in the Online Store to collect data such as the source and medium of acquiring visitors, how they behave on the website, information about devices and browsers from which they visit the site, IP address, domain, geographical data, and demographic data (age, gender), and interests.
7.8. It is possible to block Google Analytics from easily sharing information about your activity on the Online Store – for this, you can install a browser add-on provided by Google Ireland Ltd., available here: https://tools.google.com/dlpage/gaoptout?hl=en.
7.9. In connection with the possibility of the Administrator using other analytical tools provided by Google Ireland Ltd. in the Online Store, the Administrator indicates that full information on the principles of processing data of individuals visiting the Online Store (including information saved in cookies) by Google Ireland Ltd. can be found in Google’s privacy policy available at: https://policies.google.com/technologies/partner-sites.
7.10. The Administrator may use the Facebook Pixel service provided by Meta Platforms Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) in the Online Store. This service helps the Administrator measure the effectiveness of ads and learn what actions visitors to the Online Store take, as well as display personalized ads to these individuals. Detailed information on the operation of the Facebook Pixel can be found here: https://www.facebook.com/business/help/742478679120153.
7.11. Managing Facebook Pixel activities is possible through ad settings in your account on Facebook.com: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen.
8. FINAL PROVISIONS
8.1. The Online Store may contain links to other websites. The Administrator encourages you to review the privacy policy established on those websites after switching to them. This privacy policy applies only to the Online Store of the Administrator.