PRIVACY POLICY OF THE TRUEMENSKINCARE WEBSITE
We respect your privacy. The protection of personal data of users of our website https://truemenskincare.com/ (hereinafter also referred to as the “Service”) is important to us. By respecting your rights and complying with applicable legal regulations, we are committed to ensuring the security and confidentiality of the personal data collected.
In this document (hereinafter also referred to as the “Privacy Policy”), we explain, among other things, how and why we process your personal data in our Service. There is also information about the rights you have as a person whose personal data we process. Individuals using the Service are referred to in the Privacy Policy as: “Users”.
Terms used in the Privacy Policy that begin with a capital letter and are not otherwise defined in the Privacy Policy have the meaning assigned to them in the Service Regulations.
We ensure that the collected data is processed in a lawful manner and for legitimate purposes. We respect the right to privacy and guarantee that your personal data will be adequately protected. Your personal data is processed in particular 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 with regard 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 also referred to as “GDPR”.
I. Personal Data Administrator
The administrator of Users' personal data is FerrumLabs S.A. based in Warsaw (postal code: 02-566) at ul.Puławska 12/3, registered in the Register of Entrepreneurs of the National Court Register maintained by the District Court for the Capital City of Warsaw in Warsaw, XIII Economic Division of the National Court Register under the number KRS: 0000902960, NIP: 5213930091, REGON: 389092087, share capital: 154,958.50 Polish zlotys fully paid - hereinafter referred to as "Administrator.
The contact details of the Administrator are as follows:
-
correspondence address: FerrumLabs S.A., ul. Puławska 12/3; 02-566 Warsaw;
-
email address: contact@truemenskincare.com
Contact with the Administrator is also possible through the contact forms available on the Service.
II. How do we collect your data?
We collect your personal data in various ways, including
-
when you use the Service, e.g.when you register an account, place orders, or subscribe to the Newsletter;
-
when you contact us, for example, through the contact forms available on the Service;
-
when we contact you, for example, when we ask you to provide feedback on the product you purchased;
-
automatically, for example, by saving cookies on end devices.
For example, when placing an order in the Store, we collect the following personal data of the User: first name, last name, phone number, email, delivery address.
III.Why do we process your data and how long do we store it?
Your personal data will be processed for the following purposes and for the periods specified below:
| Purpose of data processing | Legal basis for data processing | Data retention period | Requirement to provide data (contractual* or statutory**) |
| Registration and management of the User's account in the Service. | Article 6(1)(a) b) GDPR (performance of the contract or taking actions at the request of the data subject before the conclusion of the contract) | From the date of account registration until the account is deleted by the User or by the Administrator. | Contractual |
| Conclusion and performance of the Sales Agreement | Article 6(1)(b) GDPR (performance of the contract or taking actions at the request of the data subject before the conclusion of the contract) | The period necessary to conclude and perform the Sales Agreement, not longer than the limitation period for claims arising from the Sales Agreement. | Contractual |
| Execution of the Subscription service | Article 6(1)(b) of the GDPR (performance of a contract or taking steps at the request of the data subject prior to entering into a contract) | Duration of the Subscription period and the period after its termination, not longer than the limitation period for claims arising from Sales Agreements concluded as a result of the execution of the Subscription. | Contractual |
| Providing responses to inquiries directed to the Administrator via the Service forms. | Article 6(1)(b)a) GDPR (consent) | The period necessary to respond to the inquiry directed to the Administrator. | Contractual |
| Provision of the Newsletter service | Article 6(1)(a) GDPR (consent) | Until the User cancels the Newsletter service (withdrawal of consent) | Contractual |
| Establishment, pursuit, or defense of claims that the Administrator may raise or that may be raised against the Administrator of data in connection with the provision of services through the Service | Article 6(1)(a)f) GDPR (legitimate interest of the administrator) | For no longer than the statute of limitations for claims (generally no longer than 6 years) | not applicable |
| User's expression of opinion on the purchased Product. | Article 6(1)(f) GDPR (legitimate interest of the administrator) | For no longer than the period of availability of the given Product in our commercial offer. | not applicable |
| Analytical and statistical purposes. Improving the Services we offer. | Article 6(1)(f) of the GDPR (legitimate interest of the data controller) | No longer than 5 years from the date of collection of personal data. | not applicable |
| Transaction settlement and bookkeeping | Article 6(1)(c) of the GDPR (fulfillment of a legal obligation imposed on the Controller) | Data is stored for the period required by law mandating the retention of accounting or tax documents. | Statutory |
| Processing of complaints | Article 6(1)(c) of the GDPR (fulfillment of a legal obligation incumbent on the Administrator) | The period necessary to process the submitted complaint, not longer than the limitation period for claims arising from the submitted complaint | Statutory |
*if the requirement to provide data is contractual, it means that providing data is a condition for concluding a contract with us or for us to provide a service on your behalf. Providing personal data is voluntary; however, the consequence of not providing data will be the inability to conclude a contract with us or the inability for us to provide a service.
**if the requirement to provide data is statutory, it means that providing data is necessary to fulfill the legal obligations imposed on us. Failure to provide data will prevent us from fulfilling these obligations and may constitute grounds for refusing to provide a particular service to you.
IV. Recipients of personal data
Your personal data may be transferred by us to third parties (so-called recipients). The transfer of data will be necessary to fulfill your order, provide other services within the Service, or improve the functionality of the Service, as well as to comply with the agreements we have entered into.
The categories of recipients to whom we may disclose your personal data are as follows:
-
Payment operators handling payments for Sales Agreements concluded in the Store;
-
courier companies or freight forwarders and carriers - in order to fulfill the delivery of the product to the User
-
service providers supplying us with technical, IT, and organizational solutions (e.g., software providers, email providers, hosting, etc.);
-
Providers of accounting, legal, and advisory services that support our business activities
-
Entities engaged in advertising and advertising measurement, who provide us with services related to targeting and measuring online advertisements;
-
Public authorities - if we are required to do so by a decision of the relevant public authority
Personal data may also be shared with recipients in connection with the use of cookies within the Service (point VII. Privacy Policy).
V. Automated processing of personal data and profiling
User's personal data may be processed in an automated manner, including in the form of profiling.
Profiling will aim to tailor sales offers to the expected preferences of the User, including based on previous purchases or previously viewed offers, or displaying personalized advertisements.
We ensure that automated data processing and profiling will not have negative effects on the User.
VI. Your rights
In connection with the processing of the User's personal data by us, the User has the following rights:
-
The right to access personal data, request their rectification, request their deletion or restriction of processing, and the right to data portability;
-
The right to object for reasons related to the particular situation of the data subject to the processing of their personal data based on our legitimate interest as the Administrator, including profiling based on this;
-
The right to object to the processing of personal data for direct marketing purposes, including profiling, to the extent that the processing is related to such direct marketing;
-
if personal data is processed by us based on your consent - the right to withdraw consent for data processing at any time.Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal
-
The right to lodge a complaint with a supervisory authority, which in Poland is the President of the Personal Data Protection Office.
-
You can exercise the rights mentioned above by contacting the Administrator - using the contact details provided in section I of the Privacy Policy.
VII. Cookie Policy
The service uses cookies (so-called "cookies"). The cookies used by the Administrator are safe for the User's device. In particular, this way it is not possible for viruses or other unwanted software or malicious software to infiltrate Users' devices. These files allow identifying the software used by the User and customizing the Service individually for each User.Cookies typically contain the domain name from which they originate, the duration of their storage on the Device, and an assigned value. The Administrator may also use other technologies with similar or identical functions to cookies. This section of the Privacy Policy contains information regarding cookies that also applies to other similar technologies used within the Service.
The Administrator uses two types of cookies:
-
Session cookies: are stored on the User's device and remain there until the session of the given browser ends.
-
Persistent cookies: are stored on the User's device and remain there until they are deleted. Ending the session of the given browser or turning off the device does not cause their removal from the User's device.
As part of the Service, various types of cookies are used for the following purposes:
-
“Essential” cookies. These cookies are essential for the proper functioning of our Service and for using the Services. Without these cookies, using the Service may be difficult or impossible, or the services you wish to use may be unavailable.
-
Performance and analytical cookies. These cookies collect information about how Users use the Service, create anonymous statistics, and allow us to improve the functioning of the Service.
-
Functional cookies.These cookies allow for the retention of choices made by the User while using the Service and services, as well as for authenticating the User in the Service and maintaining the User's session in the Service (so that the User does not have to re-enter their login and password on each subpage of the Service);
-
Advertising cookies. The Service may use advertising networks to manage the advertising content displayed in the Service. Other entities may use tracking technologies to collect information about your activities on websites in order to deliver ads that are deemed relevant to you.
Web browsing software (web browser) typically allows the storage of cookies on the User's device by default. Users can change the settings in this regard. The web browser allows for the deletion of cookies.It is also possible to automatically block cookies. Restrictions on the use of cookies may affect some functionalities available on the Service's websites. Detailed information on changing cookie settings and manually deleting them in the most popular web browsers is available in the web browser's help section.
Cookies placed on the User's end device may also be used by advertisers and partners cooperating with the Service operator. It is recommended to familiarize yourself with the privacy policies of these entities to understand the rules regarding the use of cookies utilized in statistics. Cookies may be used by advertising networks, e.g. Google network, to display ads tailored to how the user interacts with the Service.In this regard, they may retain information about the user's navigation path or the time spent on a given page.
VIII. Final Provisions
The Administrator may change the provisions of the Privacy Policy for important reasons, e.g., when the functionalities of the Service or the scope of Services provided by the Administrator change, if applicable laws change, or if the Administrator's data changes.
The Administrator will notify Users of changes to the Privacy Policy by:
-
a message visible to the User upon opening the main website of the Service and a link to the content of the new Privacy Policy
-
sending registered Users information about the change in the Privacy Policy along with a link to the consolidated text of the Privacy Policy via email.
If you continue to use the Service and our services after the changes are made, we will consider that you have agreed to the changes in the Privacy Policy.