§ 1. General information
Who is the administrator of your data?
- The administrator of personal data (ADO) is Laguna Fabryka Okuć S.A., based in Gdańsk (80-298), ul. Maszynowa 32A, entered into the Register of Entrepreneurs of the National Court Register kept by the District Court Gdańsk-Północ in Gdańsk, 7th Commercial Division of the National Court Register, under the KRS number: 0000936019, NIP: 5252564348, REGON: 146860844. The administrator of personal data is also the Seller and Service Provider of IT systems supporting Laguna Fabryka Okuć.
- Contact with the Administrator regarding the processed personal data is possible by e-mail to the following address: firstname.lastname@example.org.
§2. Personal data protection
How does Laguna protect personal data?
- Personal data is processed 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 the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) (Official Journal of the European Union Legislation: 2016.05.04).
- Personal data means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, be directly or indirectly, in particular by reference to an identifier such as first and last name, identification number, location data, an online identifier, or to one or more specific factors determining the physical, physiological, genetic, mental, economic, cultural or social identity of a natural person.
- As a rule, providing personal data is voluntary and takes place with your consent, but in certain specific cases, consent may be necessary. Failure to consent may result in the inability to use all the functionalities offered by Laguna properly.
- Personal data may also be processed without consent when it is necessary to fulfill the Administrator’s legal obligation (for example, personal data is necessary to fulfill statutory obligations, including in particular accounting and tax obligations), and the lack of data will prevent fulfilling these obligations and when the processing results from the legitimate interest of the Administrator.
- Laguna uses technical and organizational measures to ensure the protection of personal data while exercising special care to ensure that the personal data is:
a. processed in accordance with the law, in a reliable and transparent manner
b. collected for specific, explicit, and legitimate purposes,
c. adequate, relevant and limited to the purpose for processing the data,
d. stored in a form that allows your identification for no longer than is necessary to achieve the purpose of processing,
e. personal data is processed in a manner that ensures appropriate protection of personal data, including protection against unauthorized or unlawful processing and accidental loss, destruction, or damage, by means of appropriate technical and organizational measures.
- Laguna has implemented appropriate technical and organizational measures to ensure that data processing complies with applicable regulations. These measures are reviewed and updated when necessary.
What data do we use? How long is the data stored?
- The Administrator collects personal data to provide services offered by Laguna and performs activities at the data subject’s request, including inter alia, concluding a contract, performing the contract, and providing after-sales service.
- The Administrator processes (maximum scope) the following personal data:
a. data provided in the forms, including the account registration form, contact form, order form, data being the content of the contracts, i.e., first and last name, e-mail address, date of birth, correspondence address, delivery address;
b. data from other sources, in particular, information collected in the form of cookies, such as device ID, MAC address, IP address, operating system, device settings, language setting, browser type, data on users’ activity on our websites, and information on interactions with shared content;
c. first and last name, e-mail address, phone number, delivery address (street, building number, unit/suite number, zip code, city, country), home address, if different from the delivery address. In the case of customers running a business, the data identifying the company will also be processed (company name, tax identification number (NIP), address of the business/seat), and data identifying the customer’s representative.
- As a rule, the collected personal data is processed for the period necessary for the performance of contracts and for Laguna to fulfill its obligations under generally applicable provisions.
- Personal data is processed for the periods resulting from the applicable legal provisions regarding the limitation of claims.
- Data processed on the basis of consent are processed and stored by Laguna until its withdrawal.
- The data used on the basis of legitimate interest will be stored for the period necessary for its implementation or until an objection is raised if Laguna deems the objection to be justified.
What are the grounds for data processing? For what purposes do we use the data?
- The processing of personal data is lawful under Article 6(1) of the GDPR. After meeting certain conditions, the following can be distinguished among the grounds on which we process personal data:
a. Article 6(1)(a) of the GDPR – the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
b. Article 6(1)b of the GDPR – 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;
c. Article 6(1)(c) of the GDPR – processing is necessary for compliance with a legal obligation to which the Administrator is subject;
d. Article 6(1)(f) of the GDPR– 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, in particular where the data subject is a child.
- The possible purposes of personal data processing by the Administrator include:
a. conclusion and performance of contracts for the provision of services or taking actions related to the website at the request of a future Customer prior to entering into a contract (personal data is therefore processed to carry out activities related to Laguna websites so that Customers can fully use the functionality and the benefits they offer, including placing orders without the need to fill out purchase forms each time, manage consents on the website, etc.);
b. conclusion and implementation of the Sales Agreement or taking action at the request of the future Customer before its conclusion (personal data are needed to complete the order and correctly perform the concluded contract – without appropriate information, Laguna will not be able to book or send specific products or contact about them);
c. receiving and processing complaints (taking care of the quality of the offered products, Laguna offers Customers only the highest quality solutions – despite this, Laguna is not able to completely exclude production errors that have not been detected during our strict quality control);
d. presenting ads, offers, or sales, regarding products and services offered by our business partners and us, mainly to provide electronic services;
e. evaluation and analysis of the activity of Customers in the mode of automated processing of Personal Data (profiling) in order to present ads, offers, sales, and products tailored to the interests of Customers, in particular as part of the implementation of electronic services and with the help of market and statistical analyzes (sales, services, and ads offered in this way, will not directly influence the decisions made by Customers);
f. conducting correspondence with Customers and responding to it,
g. fulfilling legal obligations resulting from the regulations, including, in particular, tax and accounting regulations, especially during the implementation of paid contracts;
h. implementation of the Administrator’s legitimate interests, particularly to pursue claims and defend against claims.
What are the rights of the data subject?
- In accordance with applicable law, the data subject has the right to request access to the processed data, rectify it, delete or limit processing, object to the processing of data, and the right to transfer data. In the event of prior consent to the processing, the data subject may also exercise the right to withdraw it at any time.
- Withdrawal of consent during the processing of personal data does not affect the lawfulness of the earlier processing.
- Fulfilling all requests regarding the processed personal data will not be possible to the extent that Laguna is bound by applicable regulations.
What to do if you believe that personal data is being processed inappropriately?
- You can exercise your rights via e-mail at email@example.com. Upon receipt of the message, we will notify you as soon as possible about the actions taken or the reasons for refusing to take them.
- If you are not satisfied with the actions taken or the processing and protection of personal data being processed, you are entitled to file a complaint to the supervisory body – the President of the Office for Personal Data Protection.
Is personal data transferred to third parties?
- Personal data may be transferred to service providers and entities that we have engaged in implementing contracts concluded with Customers, and that provide services necessary for the proper operation of websites, including the implementation of contracts, websites, B2b portal, or e-store (for example, couriers, software suppliers, payment service providers).
- The data is disclosed to a limited extent. The entities to which we disclose the data have been obliged to maintain confidentiality and secrecy, and based on appropriate agreements, they have also been obliged to use the data only for the purposes for which the data was entrusted to them while maintaining protection principles at least like those of Laguna.
- Exceptionally, depending on the service provider, entities to whom we transfer personal data may independently define the purposes and methods of data processing in the scope of contracts concluded with us and applicable legal provisions that bind these entities (these are, in particular postal operators, transport service providers and law firms legal services of which we use).
- Laguna provides personal data to the relevant state authorities under applicable law.
- If you consent to cookies (hereinafter referred to as Cookies), the recipients of personal data may also be external service providers responsible for delivering content and marketing messages. More information in the Cookies section.
- As a rule, as part of Laguna’s activities, we do not anticipate circumstances in which your personal data will be transferred to countries outside the European Economic Area.
a. Exceptionally, your data may be transferred to our data processing partners outside the European Economic Area (EEA), mainly the United States.
b. In the event of a possible data transfer, the data will be transferred only to the extent necessary for the provision of services by these partners to Laguna, in particular IT services.
c. The security of your data is ensured by standard contractual clauses approved by the European Commission. We also try to ensure that our partners are covered by the so-called Privacy Shield.
d. A copy of the security measures we use regarding the data transfer to countries outside the EEA can be obtained from the Administrator after prior contact.
Marketing matters, and how to unsubscribe from receiving information from Laguna?
- As part of using Laguna’s IT services (including e-store, B2B portal, websites), you can agree to receive additional marketing information about our products and the services we offer, as well as products and services offered by our partners.
- As part of the above consent, you agree to receive by electronic means to the e-mail address provided commercial information about products and services offered by Laguna and commercial information for marketing purposes of entities cooperating with Laguna within the meaning of the Act on the provision of electronic services of July 18, 2002 (Journal of Laws of 2020, item 334).
- Cookies are small text files saved by a web browser on computers, tablets, phones, or other mobile devices. Cookies are designed to store information to identify you and your browser and remember recent activities.
- Cookies are divided into necessary and non-necessary for the proper provision of services.
- The Administrator may use Google Analytics services provided by Google Inc (1600 Amphitheater Parkway, Mountain View, CA 94043, USA), which helps analyze traffic on Laguna websites. The data collected in this way is processed as part of the above services in an anonymized manner (these are so-called operational data that prevent the identification of a person) to generate statistics helpful in the administration of websites. These data are aggregated and anonymous in nature, i.e., they do not contain identifying features (personal data) of persons visiting websites. The Administrator, using the above services, collects data such as the sources and medium of obtaining visitors to Laguna websites and the manner of their behavior on websites, information on devices and browsers from which they visit the website, IP and domain, geographic data and demographic data (age, gender) and interests.
§ 3. Final provisions
- As part of the electronic services, including the online store and websites, we make every effort to ensure that your personal data is subject to the broadest possible protection. However, Laguna websites may contain links to other websites.