PRIVACY POLICY

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1. This Privacy Policy governs the processing of personal data obtained through the hdrey.com online store (hereinafter referred to as the “Internet Store”).
   
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2. The owner of the Online Store and, at the same time, the data administrator is ESTETYCZNA GRUPA SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ based in Całowanie (05-480), 103E Całowanie Street, entered in the Register of Entrepreneurs of the National Court Register kept by the District Court for the m. st. of Warsaw in Warsaw, XIII Economic Department of the National Court Register under the KRS number 0000683399, with the share capital of PLN 5,000, NIP: 7252207626, REGON: 367580007, hereinafter referred to as ESTETYCZNA GRUPA SP. Z O.O..
   
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3. Personal data collected by ESTETYCZNA GRUPA SP. Z O.O. via the Online Store are processed in accordance with the Regulation of the European Parliament and of the Council (EU) 2016/679 of April 27, 2016 on the protection of natural persons in relation to the processing of personal data and on the free flow of such data and repealing Directive 95/46/EC (General Data Protection Regulation), also referred to as RODO.
   
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4. ESTHETIC GROUP SP. Z O.O. takes special care to respect the privacy of Customers visiting the Online Store.
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§ 1 Type of data processed, purposes and legal basis

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1. ESTHETIC GROUP SP. Z O.O. collects information concerning natural persons performing a legal action not directly related to their activity, natural persons conducting business or professional activity on their own behalf, and natural persons representing legal persons, or organizational units which are not legal persons, to whom legal capacity is granted by law, hereinafter collectively referred to as Customers.
   
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2. Customers' personal data are collected in the case of:
   
   a) account registration in the Online Store, in order to create an individual account and manage this account. Legal basis: necessity for the execution of the contract for the provision of the Account service (Article 6(1)(b) of the RODO);
   
   b) placing an order in the Online Store, in order to execute the sales contract. Legal basis: indispensability for the execution of the sales agreement (Article 6(1)(b) RODO);
   
   c) subscription to the newsletter (Newsletter), for the purpose of executing the agreement the subject of which is the service provided electronically. Legal basis - consent of the data subject for the performance of the contract for the Newsletter service (Article 6(1)(a) RODO);
   
   d) use of the contact form service in the Online Store for the performance of the contract for the electronically provided service. Legal basis: necessity for the performance of the contract for the provision of the contact form service (Article 6(1)(b) RODO).
   
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3. In the case of registering an account in the Online Store, the Customer shall provide:
   a) e-mail address.
   
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4. When registering an account with the Online Store, the Customer may log in using a one-time six-digit verification code, which is sent to his/her e-mail address.
   
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5. When placing an order in the Online Store, the Customer shall provide the following data:
   
   a) e-mail address;
   
   b) address data:
   postal code and city;
   country (state);
   -street with house/apartment number.
   
   c) first and last name;
   
   d) telephone number.
   
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6. For Entrepreneurs, the above data scope is further extended by:
   
   a) the company of the Entrepreneur;
   
   b) Tax ID number.
   
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7. In the case of using the Newsletter service, the Customer provides only his/her e-mail address.
   
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8. In case of using the contact form service, the Customer shall provide the following data:
   
   a) e-mail address;
   
   b) first name;
   
   c) telephone number.
   
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9. When using the Store Website, additional information may be collected, in particular: the IP address assigned to the Customer's computer or the external IP address of the Internet provider, domain name, browser type, access time, type of operating system.
   
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10. Navigation data may also be collected from Customers, including information about links and references they choose to click on or other actions taken on the Online Store. Legal basis - legitimate interest (Article 6(1)(f) RODO), consisting in facilitating the use of services provided electronically and improving the functionality of such services.
    
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11. For the purpose of establishing, investigating and enforcing claims, certain personal data provided by the Customer in the course of using the functionality on the Online Store may be processed, such as name, surname, data on the use of services, if the claims arise from the way the Customer uses the services, other data necessary to prove the existence of the claim, including the extent of the damage suffered. Legal basis - legitimate interest (Article 6(1)(f) RODO), consisting in the establishment, investigation and enforcement of claims and defense against claims in proceedings before courts and other state authorities.
    
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12. Submission of personal data to ESTETYCZNA GRUPA SP. Z O.O. is voluntary, in connection with concluded sales contracts or provision of services via the Store's Website, with the reservation, however, that failure to provide the data specified in the forms in the Registration process prevents the Registration and establishment of a Customer Account, and in the case of placing an order without the Registration of a Customer Account will prevent the placement and processing of the Customer's order.
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§ 2 To whom the data are shared or entrusted and how long they are kept?

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1. The Customer's personal data is transferred to the service providers used by ESTETYCZNA GRUPA SP. Z O.O. in the operation of the Online Store. Service providers to whom personal data is transferred, depending on contractual arrangements and circumstances, are either subject to the instructions of ESTETIC GROUP SP. Z O.O. as to the purposes and means of processing such data (processors), or independently determine the purposes and means of processing (controllers).
   
   a)Processors. AESTHETIC GROUP SP. Z O.O. uses suppliers who process personal data only on the instruction of ESTETIC GROUP SP. Z O.O.. These include, but are not limited to, vendors providing hosting services, accounting services, providing systems for marketing, systems for analyzing traffic to the Online Store, systems for analyzing the effectiveness of marketing campaigns;
   
   b) Administrators. AESTHETIC GROUP SP. Z O.O. uses suppliers who do not act solely on instructions and determine themselves the purposes and uses of Customers' personal data. They provide electronic payment and banking services.
   
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2. Location. Providers are based in Poland and in other countries of the European Economic Area (EEA).
   
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3. Customer's personal data are stored:
   
   a) If the basis for processing personal data is consent, then the Customer's personal data are processed by ESTETYCZNA GRUPA SP. Z O.O. as long as the consent is not revoked, and after revocation of consent for a period of time corresponding to the period of limitation of claims that may be raised by ESTETYCZNA GRUPA SP. Z O.O. and which may be raised against it. Unless a specific provision provides otherwise, the statute of limitations is six years, and for claims for periodic benefits and claims related to the conduct of business activity - three years.
   
   b) If the basis for data processing is the performance of a contract, then the Client's personal data are processed by ESTETYCZNA GRUPA SP. Z O.O. for as long as it is necessary to perform the contract, and after that time for a period corresponding to the period of limitation of claims. Unless a specific provision provides otherwise, the statute of limitations is six years, and for claims for periodic benefits and claims related to the conduct of business - three years.
   
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4. When making a purchase in the Online Store, personal data may be transferred, depending on the Client's choice, to the following entities for the purpose of delivering the ordered goods:
   
   a)courier company;
   
   b) InPost Paczkomaty Sp. z o.o., based in Cracow, providing delivery services and operating a system of post office boxes (Paczkomaty).
   
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5. When the Customer chooses to pay via the przelewy24.pl system, his/her personal data are transferred to the extent necessary for the execution of the payment to PayPro S.A. with its registered seat in Poznan (60-198 Poznan, Pastelowa 8, 60-198), entered in the register of entrepreneurs kept by the District Court Poznan - Nowe Miasto and Wilda in Poznan, VIII Economic Department of the National Court Register under the KRS number 0000347935, NIP 7792369887, Regon 301345068.
   
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6. Navigation data may be used in order to provide better service to Customers, analyze statistical data and adjust the Internet Store to Customers' preferences, as well as to administer the Internet Store.
   
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7. When a Customer subscribes to a newsletter (Newsletter) to his/her e-mail address ESTETYCZNA GRUPA SP. Z O.O. will send electronic messages containing commercial information about promotions and new products available in the Internet Shop.
   
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8. When a request is made, ESTETYCZNA GRUPA SP. Z O.O. shall make personal data available to authorized state authorities, in particular the organizational units of the Prosecutor's Office, the Police, the President of the Office of Personal Data Protection, the President of the Office of Competition and Consumer Protection or the President of the Office of Electronic Communications.
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§ 3 Cookie mechanism, IP address

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1. The Online Store uses small files, called cookies. They are saved by ESTETYCZNA GRUPA SP. Z O.O. on the final device of the person visiting the Online Store, if the Internet browser allows it. A cookie usually contains the name of the domain from which it originated, its “expiration time” and an individual random number identifying the cookie. The information collected through files of this type helps to customize the products offered by ESTETYCZNA GRUPA SP. Z O.O. products to the individual preferences and real needs of visitors to the Online Store. They also give the possibility to develop general statistics of visits to the presented products in the Internet Shop.
   
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2. ESTHETIC GROUP SP. Z O.O. uses two types of cookies:
   
   a)Session cookies: when the session of a given browser ends or the computer is turned off, the stored information is deleted from the device's memory. The mechanism of session cookies does not allow the collection of any personal data or any confidential information from the Clients' computers.
   b) Permanent cookies: are stored in the memory of the Client's final device and remain there until they are deleted or expire. The mechanism of permanent cookies does not allow the collection of any personal data or any confidential information from the Clients' computer.
   
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3. ESTHETIC GROUP SP. Z O.O. uses its own cookies in order to:
   
   a) authenticate the Customer in the Internet Shop and ensure a Customer session in the Internet Shop (after logging in), thanks to which the Customer does not have to re-enter his/her login and password on each sub-page of the Internet Shop;
   
   b) analysis and research, as well as audience auditing, and in particular to create anonymous statistics which help to understand how the Customers use the Internet Shop's Website, which makes it possible to improve its structure and content.
   
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4. ESTHETIC GROUP SP. Z O.O. uses external cookies in order to:
   
   a) popularize the Internet Store with the help of the Instagram service (external cookie administrator: Instagram LLC.based in the USA);
   
   b) popularize the Internet Store with the help of the facebook.com social network (external cookie administrator: Meta Platforms Ireland Limited, based in Ireland);
   
   c) popularization of the Online Store through the website of TikTok Technology Limited, which is registered in Ireland with its registered office at 10 Earlsfort Terrace, Dublin, D02 T380, Ireland, under number 635755;
   
   d) presentation of multimedia content on the Website, which is downloaded from the external website www. youtube.com (administrator of external cookies: Google Inc. based in the USA);
   
   e) presentation on the information pages of the Store, a map indicating the location of the office of ESTETYCZNA GRUPA SP. Z O.O., by means of maps.google.com website (external cookie administrator: Google Inc. based in the USA);
   
   f) collection of general and anonymous statistical data by means of Google Analytics tools (external cookie administrator: Google LLC based in the USA);
   
   g) presentation of Reliable Regulations Certificate by means of rzetelnyregulamin.pl website (external cookie administrator: Rzetelna Grupa sp. z o.o. based in Warsaw).
   
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5. The cookie mechanism is safe for the computers of the Online Store's Customers. In particular, it is not possible to get viruses or other unwanted software or malware on Customers' computers via this route. However, in their browsers, Customers have the option to limit or disable the access of cookies to their computers. If this option is used, the use of the Online Store will be possible, except for the functions that by their nature require cookies.
   
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6. The following is how you can change the settings of popular web browsers regarding the use of cookies:
   
   a) browser Chrome and Chrome Mobile;
   
   b) browser Samsung Browser.
   
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7. ESTHETIC GROUP SP. Z O.O. may collect Customers' IP addresses. An IP address is a number assigned to the computer of a person visiting the Online Store by an Internet Service Provider. The IP number allows access to the Internet. In most cases, it is assigned to a computer dynamically, i.e. it changes each time it connects to the Internet. The IP address is used by ESTETYCZNA GRUPA SP. Z O.O. in diagnosing technical problems with the server, creating statistical analyses (e.g. determining from which regions we record the highest number of visits), as information useful in administering and improving the Internet Shop, as well as for security purposes and possible identification of server-overloading, unwanted automatic programs for browsing the contents of the Internet Shop.
   
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8. The Internet Shop contains links and references to other websites. ESTETYCZNA GRUPA SP. Z O.O. is not responsible for the privacy policies on them.
   
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§ 4 Rights of data subjects

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1. Right to withdraw consent - legal basis: Article 7(3) RODO.
   
   a) The customer has the right to withdraw any consent that he/she has given to ESTETYCZNA GRUPA SP. Z O.O..
   
   b) Withdrawal of consent has effect from the moment of withdrawal of consent.
   
   c) Withdrawal of consent does not affect the processing performed by ESTETYCZNA GRUPA SP. Z O.O. in accordance with the law prior to its withdrawal.
   
   d) Withdrawal of consent does not entail any negative consequences for the Client, however, it may prevent further use of services or functionalities that, in accordance with the law, ESTETYCZNA GRUPA SP. Z O.O. may provide only with consent.
   
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2. Right to object to the processing of data -legal basis: Article 21 RODO.
   
   a) The customer has the right at any time to object - for reasons related to his/her particular situation - to the processing of his/her personal data, including profiling, if ESTETIC GROUP SP. Z O.O. processes his/her data on the basis of a legitimate interest, such as marketing of products and services of ESTETYCZNA GRUPA SP. Z O.O., keeping statistics on the use of particular functionalities of the Online Store and facilitating the use of the Online Store, as well as satisfaction surveys.
   
   b) Resignation in the form of an e-mail from receiving marketing messages regarding products or services will mean that the Client objects to the processing of his/her personal data, including profiling for these purposes.
   
   c) If the Client's objection proves to be legitimate and ESTETETIC GROUP SP. Z O.O. will have no other legal basis for the processing of personal data, the Client's personal data will be deleted, against the processing of which, the Client has raised an objection.
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3. Right to erasure of data (“right to be forgotten”) - legal basis: article 17 of RODO.
   
   a) The Client has the right to demand erasure of all or some of his/her personal data.
   
   b) The customer has the right to request deletion of personal data if:
   
   - the personal data are no longer necessary for the purposes for which they were collected or for which they were processed;
   
   - he/she has withdrawn a specific consent, to the extent that the personal data were processed based on his/her consent;
   
   - he/she has objected to the use of his/her data for marketing purposes;
   
   - the personal data are processed unlawfully;
   
   - the personal data must be deleted in order to comply with a legal obligation under Union law or the law of a Member State to which ESTETYCZNA GRUPA SP. Z O.O. is subject to;
   
   - personal data was collected in connection with the offering of information society services.
   
   c) Despite the request for deletion of personal data, due to the filing of an objection or withdrawal of consent, ESTETIC GROUP SP. Z O.O. may retain certain personal data to the extent that the processing is necessary to establish, assert or defend claims, as well as to comply with a legal obligation requiring processing under Union or Member State law to which ESTETIC GROUP SP. Z O.O.. This applies in particular to personal data including: name, surname, e-mail address, which data are retained for the purpose of processing complaints and claims related to the use of ESTETYCZNA GRUPA SP. Z O.O., or additionally the address of residence / mailing address, order number, which data are retained for the purpose of considering complaints and claims related to the concluded sales agreements or provision of services.
   
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4. Right to limit processing of data - legal basis: Article 18 RODO.
   
   a) The customer has the right to request limitation of processing of his personal data. Submitting a request, until it is considered, prevents the use of certain functionalities or services, the use of which will involve the processing of data covered by the request. ESTETYCZNA GRUPA SP. Z O.O. will also not send any communications, including marketing communications.
   
   b) The customer has the right to request the restriction of the use of personal data in the following cases:
   
   - when he/she questions the correctness of his/her personal data - then ESTETIC GROUP SP. Z O.O. restricts their use for the time needed to verify the correctness of the data, but no longer than for 7 days;
   
   - when the processing of the data is unlawful, and instead of deleting the data, the Customer requests the restriction of their use;
   
   - when the personal data are no longer necessary for the purposes for which they were collected or used but they are needed by the Customer to establish, assert or defend claims;
   
   - when he/she has objected to the use of his/her data, in which case the restriction shall be for the time needed to consider whether, due to the particular situation, the protection of the Client's interests, rights and freedoms outweighs the interests pursued by the Administrator in processing the Client's personal data.
   
   
5. Right of access to data - legal basis: Article 15 RODO.
   
   a) The Customer has the right to obtain confirmation from the Administrator as to whether it is processing personal data, and if this is the case, the Customer has the right:
   
   - gain access to his/her personal data;
   
   - obtain information about the purposes of processing, the categories of personal data processed, the recipients or categories of recipients of such data, the planned period of storage of the Customer's data or the criteria for determining this period (when it is not possible to determine the planned period of data processing), the Customer's rights under the RODO and the right to lodge a complaint with a supervisory authority, the source of such data, automated decision-making, including profiling, and the safeguards applied in connection with the transfer of such data outside the European Union;
   
   - obtain a copy of its personal data.
   
   
6. Right to rectification of data - legal basis: article 16 of the RODO.
   
   a) The Customer has the right to request from the Administrator the immediate rectification of personal data concerning him/her that is incorrect. Taking into account the purposes of the processing, the Customer to whom the data pertains has the right to request the completion of incomplete personal data, including by providing an additional statement, by addressing the request to the email address in accordance with §6 of the Privacy Policy.
   
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7. Right to data portability - legal basis: Article 20 of the RODO.
   
   a) The Customer has the right to receive his/her personal data that he/she has provided to the Administrator and then send it to another personal data controller of his/her choice. The customer also has the right to request that the personal data be sent by the Administrator directly to such an administrator, if technically possible. In such a case, the Administrator will send the Customer's personal data in the form of a file in csv format, which is a commonly used, machine-readable format that allows sending the received data to another personal data controller.
   
   
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8. When the Customer requests an entitlement under the above rights, ESTETIC GROUP SP. Z O.O. fulfills the request or refuses to fulfill it immediately, but no later than within one month after receiving it. However, if - due to the complexity of the request or the number of requests - ESTETYCZNA GRUPA SP. Z O.O. will not be able to fulfill the request within one month, it will fulfill it within another two months informing the Client in advance - within one month of receiving the request - about the intended extension of the deadline and the reasons for it.
   
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9. The Client may report to the Administrator complaints, inquiries and requests concerning the processing of his/her personal data and the exercise of his/her rights.
   
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10. The Client has the right to request ESTETYCZNA GRUPA SP. Z O.O. to provide a copy of the standard contractual clauses by directing the request in the manner indicated in §6 of the Privacy Policy.
    
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11. The Customer has the right to lodge a complaint with the President of the Office for Personal Data Protection, regarding violation of his/her rights to personal data protection or other rights granted under the RODO.
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§ 5 Security Management - Password

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1. ESTHETIC GROUP SP. Z O.O. provides Customers with a secure and encrypted connection when transferring personal data and when logging into the Customer Account on the Website. ESTETYCZNA GRUPA SP. Z O.O. uses SSL certificate issued by one of the world's leading companies in the field of security and encryption of data transmitted over the Internet.
   
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2. In the event that a Customer with an account on the Online Store has lost his/her access password in any way, the Online Store shall allow a new password to be generated. ESTETYCZNA GRUPA SP. Z O.O. does not send password reminders. The password is stored in an encrypted form, in a way that makes it impossible to read. In order to generate a new password, the e-mail address must be provided in the form available under the link “You have forgotten your password”, provided at the login form for the account in the Online Store. The Customer will receive an e-mail message to the e-mail address provided during registration or saved in the last change of the account profile, containing a redirection to a dedicated form available on the Store's Website, where the Customer will have the opportunity to set a new password.
   
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3. ESTHETIC GROUP SP. Z O.O. never sends any correspondence, including electronic correspondence with a request to provide login data, in particular the password to access the Customer's account.
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§ 6 Changes to Privacy Policy

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1. The Privacy Policy may be subject to change, of which ESTETIC GROUP SP. Z O.O. will inform the Customers 7 days in advance.
   
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2. Please direct any questions related to the Privacy Policy to: shop@hdrey.com
   
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3. Date of last modification: 10.02.2025
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