Privacy policy

CONTENTS:

GENERAL PROVISIONS
GROUNDS FOR PROCESSING
PURPOSE, BASIS AND DURATION OF DATA PROCESSING IN THE WEBSHOP
RECIPIENTS OF DATA IN THE ONLINE SHOP
WEBSHOP PROFILING
RIGHTS OF THE DATA SUBJECT
COOKIES IN THE WEBSHOP AND ANALYTICS
FINAL PROVISIONS

1. GENERAL PROVISIONS

1.1. This privacy policy of the Online Shop is for information purposes only, which means that it does not constitute a source of obligations for Service Recipients or Customers of the Online Shop. The privacy policy primarily contains rules concerning the Administrator's processing of personal data in the Online Shop, including the grounds, purposes and duration of personal data processing and the rights of data subjects, as well as information on the use of cookies and analytical tools in the Online Shop.

1.2. The administrator of the personal data collected through the Internet Shop is PRZEMYSŁAW WARDZYŃSKI, doing business under the name VORTEX CONSULTING PRZEMYSŁAW DANIEL WARDZYŃSKI, entered in the Central Register of Business Activity and Information of the Republic of Poland, maintained by the minister responsible for economic affairs, holding: business address and address for delivery: ul. Patriotów 110/lok. 112B, 04-844 Warsaw, NIP 5262261767, REGON 386084236, e-mail address: sales@vortexvr.hu, - hereinafter referred to as the "Administrator" and being at the same time the Service Provider of the Internet Shop and the Seller.

1.3. Personal data in the Online Shop are processed by the Administrator in accordance with the applicable legal provisions, in particular 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 in relation to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) - hereinafter referred to as "GDPR" or "GDPR Regulation". Official text of the GDPR Regulation: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32016R0679

1.4. The use of the Online Shop, including making purchases, is voluntary. Similarly, the related provision of personal data by the Customer or Client using the Internet Shop is voluntary, subject to two exceptions: (1) conclusion of agreements with the Administrator - failure to provide, in the cases and to the extent indicated on the website of the Internet Shop and in the Regulations of the Internet Shop and this privacy policy, personal data necessary for the conclusion and performance of a Sales Agreement or an agreement for the provision of Electronic Services with the Administrator results in the impossibility of concluding such an agreement. The provision of personal data in such a case is a contractual requirement and if the data subject wishes to conclude a given agreement with the Administrator, he/she is obliged to provide the required data. Each time the scope of data required to conclude a contract is indicated beforehand on the website of the Internet Shop and in the Terms and Conditions of the Internet Shop; (2) statutory obligations of the Administrator - providing personal data is a statutory requirement resulting from generally applicable laws imposing an obligation to process personal data on the Administrator (e.g. processing of data for tax or accounting purposes), and failing to provide such data will make it impossible for the Administrator to fulfil those obligations.

1.5. The controller shall take particular care to protect the interests of the persons whose personal data it processes and in particular shall be responsible and ensure that the data it collects are: (1) processed lawfully; (2) collected for specified, legitimate purposes and not subjected to further processing incompatible with those purposes; (3) substantively correct and adequate in relation to the purposes for which they are processed; (4) kept in a form which permits identification of data subjects for no longer than is necessary to achieve the purpose of the processing; and (5) processed in a manner which ensures appropriate security of personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, by means of appropriate technical or organisational measures.

1.6. Taking into account the nature, scope, context and purposes of the processing and the risk of violation of the rights or freedoms of natural persons of varying probability and seriousness, the Administrator shall implement appropriate technical and organisational measures to ensure that the processing is carried out in accordance with the GDPR Regulation and to be able to demonstrate this. These measures shall be reviewed and updated as necessary. The Administrator shall apply technical measures to prevent the acquisition and modification by unauthorised persons of personal data transmitted electronically.

1.7. All words, phrases and acronyms appearing in this privacy policy and beginning with a capital letter (e.g. Seller, Online Shop, Electronic Service) shall be understood in accordance with their definition contained in the Rules and Regulations of the Online Shop available on the pages of the Online Shop.

2. GROUNDS FOR PROCESSING

2.1. The controller is entitled to process personal data where, and to the extent that, one or more of the following conditions are met: (1) the data subject has given his or her consent to the processing of his or her personal data for one or more specified purposes; (2) the processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject prior to entering into a contract; (3) the processing is necessary for compliance with a legal obligation incumbent on the Controller; or (4) processing is necessary for the purposes of the legitimate interests pursued by the Controller 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.

2.2. The processing of personal data by the Controller requires in each case the existence of at least one of the grounds indicated in point. 2.1 of the Privacy Policy. The specific grounds for the Administrator's processing of the personal data of Service Recipients and Customers of the Internet Shop are indicated in the next section of the privacy policy - with reference to the given purpose of personal data processing by the Administrator.

3. PURPOSE, BASIS AND DURATION OF DATA PROCESSING IN THE WEBSHOP

3.1. In each case, the purpose, basis and period and recipients of the personal data processed by the Administrator result from the activities undertaken by the respective Customer or Client in the Online Shop or by the Administrator. For example, if a Customer decides to make a purchase from the Online Shop and chooses personal collection of the purchased Product instead of courier delivery, his/her personal data will be processed for the purpose of performing the concluded Sales Agreement, but will no longer be made available to the carrier carrying out the delivery on behalf of the Administrator.

3.2. The Administrator may process personal data within the Online Shop for the following purposes, on the grounds and for the periods indicated in the table below:

Purpose of data processing	Legal basis for data processing	Data retention period
Performing a Sales Contract or an agreement for the provision of an Electronic Service or taking action at the request of the data subject prior to entering into the aforementioned contracts	Article 6(1)(b) of the GDPR Regulation (performance of a contract) - processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject prior to entering into a contract	The data shall be stored for the period of time necessary for the performance, termination or otherwise expiry of the concluded Sales Agreement or Electronic Service Agreement.
Direct marketing	Article 6(1)(f) of the GDPR Regulation (legitimate interest of the Administrator) - the processing is necessary for the purposes of the Administrator's legitimate interests - consisting of looking after the interests and good image of the Administrator, its Online Shop and aiming to sell Products	The data shall be stored for the period of existence of the legitimate interest pursued by the Administrator, but no longer than for the period of limitation of the Administrator's claims against the data subject on account of the Administrator's business activities. The period of limitation shall be determined by the provisions of law, in particular the Civil Code (the basic limitation period for claims related to business activities is three years, and for the Sales Agreement it is two years). The controller may not process the data for direct marketing purposes in the event of an effective objection to this effect by the data subject.
Marketing	Article 6(1)(a) of the GDPR Regulation (consent) - the data subject has consented to the processing of his/her personal data for marketing purposes by the Controller	The data is stored until the data subject withdraws his or her consent to further processing for this purpose.
Bookkeeping	Article 6(1)(c) of the GDPR Regulation in conjunction with Article 74(2) of the Accounting Act, i.e. of 30 January 2018. (Journal of Laws of 2018, item 395 as amended) - processing is necessary to fulfil a legal obligation incumbent on the Administrator	The data is retained for the period required by the law requiring the Administrator to keep the accounts (5 years, calculated from the beginning of the year following the financial year to which the data relates).
Establishing, asserting or defending claims which the Administrator may assert or which may be asserted against the Administrator	Article 6(1)(f) of the GDPR Regulation (legitimate interest of the Administrator) - processing is necessary for the purposes of the Administrator's legitimate interests - consisting of establishing, asserting or defending claims which the Administrator may raise or which may be raised against the Administrator	The data shall be stored for the period of existence of the legitimate interest pursued by the Administrator, but no longer than for the period of limitation of claims that may be raised against the Administrator (the basic limitation period for claims against the Administrator is six years).
Use of the website of the Online Shop and ensuring its proper functioning	Article 6(1)(f) of the GDPR Regulation (legitimate interest of the Administrator) - processing is necessary for the purposes of the Administrator's legitimate interests - consisting of the operation and maintenance of the Online Shop website	The data shall be stored for the period of existence of the legitimate interest pursued by the Administrator, but no longer than for the period of limitation of the Administrator's claims against the data subject on account of the Administrator's business activities. The period of limitation shall be determined by the provisions of law, in particular the Civil Code (the basic limitation period for claims related to business activities is three years, and for the Sales Agreement it is two years).
Keeping statistics and analysing traffic in the Online Shop	Article 6(1)(f) of the GDPR Regulation (legitimate interest of the Administrator) - processing is necessary for the purposes deriving from the Administrator's legitimate interests - consisting of conducting statistics and analysis of traffic in the Online Shop in order to improve the functioning of the Online Shop and increase sales of Products	The data shall be stored for the period of existence of the legitimate interest pursued by the Administrator, but no longer than for the period of limitation of the Administrator's claims against the data subject on account of the Administrator's business activities. The period of limitation shall be determined by the provisions of law, in particular the Civil Code (the basic limitation period for claims related to business activities is three years, and for the Sales Agreement it is two years).

4. RECIPIENTS OF DATA IN THE ONLINE SHOP

4.1. For the proper functioning of the Online Store, including for the performance of concluded Sales Agreements, it is necessary for the Administrator to use the services of external entities (such as a software provider, courier or payment processor). The Administrator shall only use the services of such processors who provide sufficient guarantees of the implementation of appropriate technical and organisational measures so that the processing meets the requirements of the GDPR Regulation and protects the rights of the data subjects.

4.2. Personal data may be transferred by the Controller to a third country, in which case the Controller shall ensure that this will be done in relation to a country ensuring an adequate level of protection - in accordance with the GDPR Regulation, and in the case of other countries that the transfer will take place on the basis of standard data protection clauses. The controller shall ensure that the data subject is able to obtain a copy of his/her data. The controller shall transfer the collected personal data only if and to the extent necessary for the fulfilment of the specific purpose of the processing in accordance with this privacy policy.

4.3. The transfer of data by the Administrator does not take place in every case and not to all the recipients or categories of recipients indicated in the privacy policy - the Administrator transfers data only if it is necessary for the fulfilment of the given purpose of personal data processing and only to the extent necessary for its fulfilment. For example, if the Customer uses personal collection, his/her data will not be transferred to the carrier cooperating with the Administrator.

4.4. The personal data of Service Recipients and Customers of the Online Shop may be communicated to the following recipients or categories of recipients:

carriers / forwarders / brokers couriers / entities handling the warehouse and/or dispatch process - in the case of a Customer who uses the method of Product delivery in the Internet Shop by mail or courier, the Administrator makes the collected personal data of the Customer available to the selected carrier, forwarder or intermediary performing the shipment on behalf of the Administrator, and if the shipment takes place from an external warehouse - to the entity handling the warehouse and/or dispatch process - to the extent necessary to complete the delivery of the Product to the Customer .
Entities handling electronic or credit card payments - in the case of a Customer who uses the electronic or credit card payment method in the Internet Shop, the Administrator shall make the collected personal data of the Customer available to a selected entity handling the aforementioned payments in the Internet Shop on the order of the Administrator to the extent necessary to handle the payment made by the Customer.
lenders / lessors - in the case of a Customer who uses the instalment payment method or the leasing payment method in the Internet Shop, the Administrator makes the collected personal data of the Customer available to a selected lender or lessor servicing the aforementioned payments in the Internet Shop on behalf of the Administrator to the extent necessary to service the payment made by the Customer.
service providers who supply the Administrator with technical, IT and organisational solutions enabling the Administrator to conduct his/her business activity, including the Internet Shop and the Electronic Services provided by means of it (in particular, computer software providers for running the Internet Shop, e-mail and hosting providers and providers of business management and technical support software to the Administrator) - the Administrator shall make the collected personal data of the Customer available to the chosen provider acting on his/her behalf only in the case and to the extent necessary for the performance of the given purpose of data processing in compliance with this Privacy Policy.
providers of accounting, legal or advisory services who provide accounting, legal or advisory support to the Administrator (in particular an accountancy office, a law firm or a debt collection agency) - The Administrator shall make the collected personal data of the Client available to the selected provider acting on its behalf only in the case and to the extent necessary to achieve the given purpose of data processing in accordance with this Privacy Policy.
providers of social plug-ins, scripts and other similar tools placed on the website of the Online Shop which enable the browser of the person visiting the website of the Online Shop to download content from the providers of the said plug-ins (e.g. logging in using the login data of a social network) and to transmit for this purpose to these providers personal data of the person visiting , including:
- Meta Platforms Ireland Ltd. - The Administrator uses Facebook social plug-ins (e.g. Like button, Share or login via Facebook login data) on the website of the Online Shop and therefore collects and shares the personal data of the Customer using the website of the Online Shop with Meta Platforms Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland) to the extent and in accordance with the privacy policy available here: https://www.facebook.com/about/privacy/ (this data includes information about your activities on the Online Shop website - including information about your device, sites visited, purchases made, advertisements displayed and how you use the services - regardless of whether you have a Facebook account and are logged into Facebook).

5. WEBSHOP PROFILING

5.1. The GDPR Regulation imposes an obligation on the Controller to provide information on automated decision-making, including profiling as referred to in Article 22(1) and (4) of the GDPR Regulation, and, at least in these cases, relevant information on the modalities of such decision-making, as well as on the significance and the envisaged consequences of such processing for the data subject. With this in mind, the Controller provides information on possible profiling in this section of the privacy policy.

5.2. The Administrator may use profiling on the Online Store for direct marketing purposes, but the decisions made on its basis by the Administrator do not concern the conclusion or refusal of a Sales Agreement or the possibility of using Electronic Services on the Online Store. The effect of the use of profiling in the Online Shop may be, for example, to grant a person a discount, send him/her a discount code, remind him/her of unfinished purchases, send him/her a proposal of a Product that may correspond to the person's interests or preferences or offer better conditions compared to the standard offer of the Online Shop. Despite the profiling, it is up to the individual to decide freely whether they want to take advantage of the discount or better conditions received in this way and make a purchase from the Online Shop.

5.3. Profiling in the Online Shop involves the automatic analysis or prediction of a person's behaviour on the website of the Online Shop, e.g. by adding a specific Product to the basket, browsing the page of a specific Product in the Online Shop or by analysing the previous history of purchases made in the Online Shop. The condition for such profiling is that the Administrator is in possession of the person's personal data in order to be able to subsequently send the person, for example, a discount code.

5.4. The data subject has the right not to be subject to a decision which is based solely on automated processing, including profiling, and which produces legal effects on the data subject or similarly significantly affects the data subject.

6. RIGHTS OF THE DATA SUBJECT

6.1. Right of access, rectification, restriction, erasure or portability - the data subject has the right to request from the Controller access to his/her personal data, rectification, erasure ("right to be forgotten") or restriction of processing, and has the right to object to processing, and has the right to portability of his/her data. The detailed conditions for exercising the rights indicated above are indicated in Articles 15-21 of the GDPR Regulation.

6.2. Right to withdraw consent at any time - a person whose data is processed by the Controller on the basis of expressed consent (pursuant to Article 6(1)(a) or Article 9(2)(a) of the GDPR Regulation) has the right to withdraw consent at any time without affecting the lawfulness of the processing carried out on the basis of consent before its withdrawal.

6.3. Right to lodge a complaint to the supervisory authority - the person whose data is processed by the Controller has the right to lodge a complaint to the supervisory authority in the manner and mode specified in the provisions of the GDPR Regulation and Polish law, in particular the Personal Data Protection Act. The supervisory authority in Poland is the President of the Office for Personal Data Protection.

6.4. Right to object - The data subject has the right to object at any time - on grounds relating to his or her particular situation - to the processing of personal data concerning him or her based on Article 6(1)(e) (public interest or tasks) or (f) (legitimate interest of the controller), including profiling on the basis of these provisions. In such a case, the controller shall no longer be allowed to process these personal data unless the controller can demonstrate the existence of compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or grounds for the establishment, exercise or defence of claims.

6.5. Right to object to direct marketing - where personal data is processed for the purposes of direct marketing, the data subject has the right to object at any time to the processing of personal data concerning them for such marketing, including profiling, to the extent that the processing is related to such direct marketing.

6.6. In order to exercise the rights referred to in this section of the privacy policy, the Administrator may be contacted by sending an appropriate message in writing or by e-mail to the Administrator's address indicated at the beginning of the privacy policy or by using the contact form available on the website of the Internet Shop.

7. COOKIES IN THE WEBSHOP AND ANALYTICS

7.1. Cookies are small pieces of information in the form of text files which are sent by a server and stored on the website of the Internet Shop (e.g. on the hard drive of a computer, laptop or smartphone memory card - depending on the device used by the visitor to our Internet Shop). Detailed information on cookies, as well as the history of their creation can be found, inter alia, here: https://pl.wikipedia.org/wiki/HTTP_cookie.

7.2. The cookies that may be sent by the website of the Online Shop can be divided into different types, according to the following criteria:

Because of their supplier:

1) own (created by the Administrator's website of the Online Shop) and

2) belonging to third parties (other than the Administrator)

Due to their storage period on the device of the person visiting the website of the Online Shop:

1) session (stored until you log out of the Online Shop or switch off your web browser) and

2) permanent (stored for a specific period of time, defined by the parameters of each file, or until manually deleted)

Due to the purpose of their use:

1) necessary (to enable the proper functioning of the website of the Internet Shop),

2) functional/preferential (allowing the web page of the Online Shop to be adapted to the preferences of the visitor),

3) analytical and performance analysis (gathering information about how the website of the Online Shop is used),

4) marketing, advertising and social media (gathering information about the person visiting the site of the Internet Shop for the purpose of displaying advertisements to that person, personalising them, measuring their effectiveness and conducting other marketing activities, including on websites separate from the site of the Internet Shop, such as social networks or other sites belonging to the same advertising networks as the Internet Shop)

7.3. The Administrator may process the data contained in cookies when visitors use the website of the Online Shop for the following specific purposes:

Purposes of using cookies in the Administrator's online shop	identify customers as logged in to the Online Shop and show that they are logged in (essential cookies)
	remembering the Products you have added to your shopping basket for the purpose of placing an Order (cookies required)
	storing data from completed Order Forms, surveys or login data for the Online Shop (essential and/or functional/preference cookies)
	adapting the content of the website of the Internet Shop to the individual preferences of the Customer (e.g. as regards colours, font size, page layout) and optimising the use of the pages of the Internet Shop (functional/preference cookies)
	keep anonymous statistics showing how the website of the Internet Shop is used (analytical and performance cookies)
	to display and render advertisements, to limit the number of times advertisements are displayed and to ignore advertisements that the Customer does not wish to see, to measure the effectiveness of advertisements, and to personalise advertisements, i.e. to study the behavioural characteristics of visitors to the Online Shop through anonymous analysis of their actions (e.g. repeated visits to specific pages, keywords, etc.) in order to create their profile and provide them with advertisements tailored to their anticipated interests, also when they visit other websites in the advertising network of Google Ireland Ltd. and Meta Platforms Ireland Ltd. (marketing, advertising and social media cookies)

7.4. It is possible to check in the most popular web browsers which cookies (including the duration of the cookies and their provider) are being sent at any given time by the website of the Online Shop as follows:

In the Chrome browser: (1) in the address bar, click on the padlock icon on the left, (2) go to the "Cookies" tab.	In the Firefox browser: (1) in the address bar, click on the shield icon on the left, (2) go to the "Allowed" or "Blocked" tab, (3) click on the box "Tracking cookies between sites", "Social media tracking elements" or "Content with tracking elements"	In Internet Explorer: (1) click the "Tools" menu, (2) go to the "Internet Options" tab, (3) go to the "General" tab, (4) go to the "Settings" tab, (5) click the "View Files" box
In the Opera browser: (1) in the address bar, click on the padlock icon on the left, (2) go to the "Cookies" tab.	in the Safari browser: (1) click on the "Preferences" menu, (2) go to the "Privacy" tab, (3) click on the box "Manage site data"	Regardless of the browser, using the tools available, for example, at: https://www.cookiemetrix.com/ or: https://www.cookie-checker.com/

7.5. By default, most web browsers on the market accept the storing of cookies. You can determine the conditions for the use of cookies via the settings of your own browser. This means that you can, for example, partially restrict (e.g. temporarily) or completely disable the possibility of storing cookies - in the latter case, however, this may affect some of the functionality of the Internet Shop (for example, it may not be possible to follow the path of the Order through the Order Form due to the Products not being remembered in the shopping cart during the consecutive steps of placing the Order).

7.6. Your browser's settings regarding cookies are relevant to your consent to the use of cookies by our Online Shop - in accordance with the regulations, such consent can also be expressed through your browser settings. Detailed information on how to change the settings for cookies and how to delete them yourself in the most popular web browsers is available in the help section of your web browser and on the following pages (just click on the respective link):

in Chrome browser

in Firefox

in Internet Explorer

in the Opera browser

in the Safari browser

in the Microsoft Edge browser

7.7. The Administrator may use Google Analytics, Universal Analytics services provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) on the Online Shop. These services help the Administrator keep statistics and analyse traffic on the Online Shop. The data collected is processed by the above services to generate statistics to help administer the Online Shop and analyse traffic on the Online Shop. This data is of an aggregate nature. When using the above services in the Internet Shop, the Administrator collects such data as the source and medium of obtaining visitors to the Internet Shop and their behaviour on the website of the Internet Shop, information on the devices and browsers from which they visit the website, IP and domain, geographical data and demographic data (age, gender) and interests.

7.8. It is possible for a person to easily block the release of information to Google Analytics about his or her activity on the website of the Online Shop - for this purpose, you can, for example, install a browser add-on provided by Google Ireland Ltd. available here: https://tools.google.com/dlpage/gaoptout?hl=pl.

7.9. In connection with the Administrator's possibility of using advertising and analytical services provided by Google Ireland Ltd. in the Internet Shop, the Administrator points out that full information on the principles of processing of data of visitors to the Internet Shop (including information saved in cookies) by Google Ireland Ltd. can be found in the privacy policy of Google services available at: https://policies.google.com/technologies/partner-sites.

7.10. The Administrator may use on the Online Shop the Facebook Pixel service provided by Meta Platforms Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland). This service helps the Administrator to measure the effectiveness of advertisements and to find out what actions visitors take on the Online Shop, and to display tailored advertisements to such visitors. You can find detailed information about the operation of Facebook Pixel at the following web address: https://www.facebook.com/business/help/742478679120153?helpref=page_content.

7.11. You can manage the operation of the Facebook Pixel via the ad settings in your Facebook.com account: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen.

8. FINAL PROVISIONS

8.1. The Internet shop may contain links to other websites. The Administrator urges that when you go to other websites, you should familiarise yourself with the privacy policy established there. This privacy policy applies only to the Administrator's Internet Shop.