1.What document are you dealing with?
informative, which means that it is not a source of obligation for the Customers of the Internet Shop.
2.Who is the Administrator of your Data?
The Administrator of personal data collected:
technology) or other channels of communication with the Customer.
b) obtained on the basis of the Customer’s activity on the Internet, is Brokat spółka z ograniczoną odpowiedzialnością
with its registered office in Katowice (post code: 40-860) at Gliwicka 188/3,
entered in the Register of Entrepreneurs of the National Court Register kept by the District Court of Katowice
Register of Entrepreneurs of the National Court Register kept by the District Court Katowice – Wschód in Katowice, 8th Commercial Division of the National Court Register
under the KRS number: 0000565588, holding tax identification number (NIP): 6342842136, statistical number (REGON): 361933918 and share capital of
share capital of 150.000,00 PLN (in words: one hundred and fifty thousand PLN 00/100) , contact
e-mail: firstname.lastname@example.org, tel. 883 366 008, hereinafter referred to as “Administrator” and being
Under the above contact details, you can also contact the data protection officer
data protection officer.
3.How do we take care of your data?
Customer’s personal data are processed in accordance with the Regulation of the European Parliament and of the Council
(EU) 2016/679 of 27 April 2016 on the protection of natural persons in relation to
processing of personal data and on the free movement of such data and repealing
Directive 95/46/EC (Dz.Urz.UE.L No. 119, p. 1) (hereinafter also: “RODO”) and other currently
currently in force, i.e. for the entire period of processing of specific data, provisions of the law on personal data protection
personal data. Personal data means information about an identified or identifiable
identified or identifiable natural person (hereinafter: “Personal Data”). Identifiable
a natural person is a person who can be identified, directly or indirectly, in particular
an identifier such as a name, an identification number, location data,
Internet identifier, or one or more factors specific to a physical
physiological, genetic, mental, economic, cultural or social identity of the natural person
The controller shall take special care to protect the interests of data subjects,
and in particular ensures that the data collected by it are:
(a) processed lawfully, fairly and in a manner transparent to the data subject;
(b) collected for specified, explicit and legitimate purposes and not further processed
incompatible with those purposes;
(c) adequate, relevant and limited to what is necessary for the purposes for which they are
(d) accurate and, where necessary, kept up to date;
(e) kept in a form which permits identification of the data subject for no
longer than is necessary for the purposes for which the data are processed;
f) Processed in a manner which ensures appropriate security of the Personal Data, including
protection against unlawful or unlawful processing and accidental loss,
destruction or damage, by means of appropriate technical or
4.For what purposes is your information used?
Each time, the purpose and scope of data processed by the Administrator result from the Client’s consent or
provisions of law and are further specified as a result of actions taken by the Customer in the
Online Store or as part of other communication channels with the Customer.
Possible purposes of processing the Client’s Personal Data by the Administrator include, in particular:
(a) conclusion and performance of the Service Agreement (Account) or taking action at the request of the
a) conclusion and performance of the Service Provision Agreement (Account) or taking action at the request of a future Customer prior to its conclusion (we process your data in order to maintain your
Account so that you can enjoy the benefits it offers, e.g. placing orders without
(Your data is processed in order to maintain your Account so that you can enjoy the benefits it offers, e.g. placing orders without having to fill in forms each time, accessing your purchase history, managing your consents on the site, etc.)
service etc. and to enable you to use other services available on our website);
b) conclusion and performance of a Sales Agreement, or taking action at the request of a future customer prior to its
conclusion of the Sales Agreement (we need your personal data to execute your order and perform
the concluded contract – in particular, to confirm its placement and to reserve or send the
the selected product to you, as well as to contact you in this regard, if necessary);
c) provide your personal data to ING Bank Śląski S.A. (“Bank”) in connection with:
a. a. providing the Internet Shop with the service of making available the infrastructure for
(legal basis: Article 6 (1) (f) of the Regulation).
b. handling and settlement by the Bank of payments made by customers of the
via the Internet using payment instruments (legal basis: Article 6 (1)(f) of the
c. For the purpose of verifying proper implementation by the Bank of agreements concluded with the Online Store, in
in particular to ensure protection of the interests of payers in connection with their
(legal basis: Article 6 (1) (f) of the Regulation).
d. provide your personal data to iMoje and PayPal in connection with the possibility
offer to make payment for the purchased goods.
d) provide your personal data to courier companies -Inpost and DPD in order to dispatch
order to the address indicated in the order. The data provided to the companies is the name and surname of the person
ordering, the exact address: street, apartment/home number, postal code and telephone number.
e) Receiving and processing complaints;
f) Conducting a competition, in particular selecting competition winners and realization
g) Presenting advertisements, offers or promotions (discounts) concerning Administrator’s products or services
(up-to-date list of which is available in the Internet Shop) intended for all
recipients, in particular in order to execute the Newsletter contract;
(h) evaluation and analysis of Customer activity and information, including through automated
processing of Personal Data (profiling) in order to present general advertisements, offers or
(h) assessment and analysis of activity and information concerning the Administrator’s and its partners’ products or services in a manner
The data is processed in a manner tailored to the Client’s interests (without, however, significantly affecting the Client’s decisions), in particular
in particular in order to execute the Newsletter contract, as well as market and statistical analyses
i) asserting and defending against claims, also of third parties – in the case of
i) asserting and defending against claims, also of third parties – in the event of using most of the functionalities of the Internet Shop;
j) fulfilment of legal obligations resulting from regulations, e.g. tax and accounting,
especially in the case of paid agreements;
k) correspond with Customers, including replying to Customers’ messages.
In connection with the processing of personal data for the purposes specified in point c, your personal data
personal data can be made available by the Internet store to other recipients or categories of recipients, which can be
which may be: a) ING Bank Śląski S.A. b) Imoje, c) PayPal.
In the case of transferring your personal data to the Bank in connection with the handling and settlement of
payments made by you to the Internet Shop via the Internet
In the case of transferring your personal data to the Bank in connection with the processing and settlement of payments made by you to the Online Store via the Internet
to transmit the confirmation of its execution by the Bank to the Online Store. In the event
transferring your personal data to the Bank in order for the Bank to verify the proper
performance of agreements concluded with the online store, in particular to ensure the protection of
interests of the payers in connection with their complaints, providing this data is
required to enable the execution of the agreement concluded between the online store and the
Bank. In the case of passing your personal data to Imoje and PayPal in connection with
the possibility of offering you to pay the price for the goods purchased by you
or service by Imoje and PayPal within the framework of the order agreement which includes the Imoje and
PayPal and making this formula available by the online store, providing this data and processing it
processing them for this purpose is required in connection with the business model adopted by the online store and in order to
In order to perform the contract concluded between the online store and Imoje
5. what information about you do we use?
In particular, the Administrator may process the following Personal Data of Customers:
using the Online Store:
a) Personal Data provided in the form when registering an Account, placing Orders in the Online Store
(in particular: first and last name; e-mail address; contact telephone number
(in particular: first and last name; email address; contact telephone number; address [street, house number, apartment number, postal code, city, country), address
of residence/business/office [if different from the delivery address], bank account number
bank account number, and in the case of Customers who are not consumers, additionally company name and
tax identification number [NIP]) and other data collected during the use of the Internet Shop
b) Personal Data provided in order to use the Newsletter, provided while using the
c) Personal Data provided for the purpose of participating in contests; other data, in particular data obtained
based on Customer’s activity on the Internet, including data obtained through the Internet Store
Internet Shop, or other channels of communication with the Customer, using cookies and
d) by filling in data contained in application forms that enable the Administrator to carry out
Administrator within the Facebook Service advertising campaigns/contests, the User
provides the Administrator each time with the Personal Data indicated in the form, which may
which may include in particular: name, surname, correspondence address, e-mail address, telephone number.
6. Are you obliged to provide us with your data and what are the possible consequences of their
consequences of failing to provide them?
Providing Personal Data by the Customer in the Internet Shop is voluntary, however, it is
necessary to use certain functionalities of our store for example to place an
Customer’s order and its settlement (conclusion and execution of the Sales Agreement), registration
Account, subscribe to the Newsletter, use the Imoje/Paypal service or use our
Each time the scope of data required to conclude a relevant agreement is previously indicated
in the Internet Shop (we mark the data which are necessary to conclude a
conclusion of a contract/use of a given functionality), as part of other channels of communication with the Customer
or in the Regulations. The consequence of failing to provide Personal Data may be the inability to
to perform the above actions effectively.
7. on what legal basis do we use your information?
The basis for processing your Personal Data is primarily the need to perform
contract to which he/she is a party or the need to take action at his/her request before concluding the contract (art.
6(1)(b) RODO). This applies primarily to Personal Data provided in the form
when registering an Account, placing Orders and concluding a Sales Agreement in the Online Shop,
as well as when subscribing to the Newsletter. Also in the case of Personal Data
provided to us in connection with a Customer complaint, the legal basis for their processing is
necessity to execute / service the sales agreement of the advertised goods.
For other (other) purposes, Customer Personal Data may be processed on the basis of:
(a) voluntarily expressed consents – e.g. of persons entering competitions (Article 6(1)(a)
b) binding legal regulations – when processing is necessary for the fulfilment of a legal obligation
Administrator, e.g. when on the basis of tax or accounting regulations
Administrator settles concluded sales contracts (Article 6(1)(c) of the RODO);
c) indispensability for purposes other than those mentioned above resulting from legally justified
interests pursued by the Administrator or by a third party, in particular to establish,
asserting or defending claims, corresponding with customers, also through
contact forms (including replying to customers’ messages), market analyses
and statistical analyses (Article 6(1)(f) RODO).
8. is your data subject to profiling and what does this mean for you?
Administrator for the purpose of presenting general advertisements, offers or promotions (discounts),
for the purpose of presenting general advertisements, offers or promotions (discounts) intended for all Customers in a manner tailored to the interests of a given Customer.
The Administrator can learn about the Customer’s preferences, e.g. by analysing how often the Customer visits the
The Internet Shop and whether and what products they buy. This allows for a better understanding of the
This allows us to better understand the customer’s expectations and adapt to his needs, without, however, significantly affecting his decisions. Thanks to
advanced technologies used by the Administrator, the above actions will often be
performed by the system in an automated manner, so that the content sent will be
The content will be sent in the most up-to-date manner, and the Customer will be able to quickly get acquainted with it.
9. to whom can we transfer your data?
Each time, the catalog of recipients of the Personal Data processed by the Administrator results
First of all, it results from the scope of services used by the Customer.
The list of data recipients also results from the Client’s consent or from legal regulations, and
is further specified as a result of actions taken by the Customer in the Internet Shop.
The Administrator’s partners may participate in the processing of Personal Data to a limited extent
Administrator, especially those, who technically help to run the Internet Shop efficiently,
including communication with our Customers (e.g. they support us in sending e-mails, and in case of
In case of advertising activities – also in marketing campaigns), hosting or ICT service providers, carriers
or ICT service providers, carriers or agents for Order shipment, electronic payment or card payment
entities processing electronic or credit card payments in the Internet Shop, companies
who service the software, support the Administrator in marketing campaigns, as well as
as well as providers of legal and advisory services.
10. What rights do you have?
Each Customer has the right at any time to:
(a) to lodge a complaint with the President of the Office for Personal Data Protection;
b) transfer of the Personal Data which he/she has provided to the Administrator and which are processed in an
automated manner and the processing is based on consent or on the basis of
contract, e.g. to another controller;
c) access to Personal Data (including, for example, receiving information as to which Personal Data are
d) Requests for rectification and restriction of processing (e.g. where the Personal Data is inaccurate) or
erasure of Personal Data (e.g. where it has been unlawfully processed);
e) withdrawal of any consent given to the Administrator at any time, whereby withdrawal of consent does
e) withdrawal of any consent given to the Administrator at any time, whereby withdrawal of consent does not affect processing carried out by the Administrator in accordance with the law prior to its
withdrawal of consent.
f) raise an objection to the processing of Personal Data concerning him/her carried out for the
legitimate interests of the Administrator or a third party, including in particular
in particular to processing for marketing purposes, including profiling (if there are no other
valid legitimate grounds for processing overriding the Client’s interests).
11. for how long will we store your data?
Personal Data can be stored for the period of use of the Online Store , in the case of
in the case of marketing activities – until the Customer raises an objection, and if related to
If related to cookies and similar technologies, depending on technical issues, until the deletion of these
files using browser / device settings (while deleting files is not always
deletion of files is not always the same as the deletion of Personal Data obtained through these files, hence the possibility to object)
If the processing of Personal Data is subject to the Customer’s consent, the Personal Data may be
processed until such consent is withdrawn.
In any case:
(a) Personal Data will also be stored if legislation (e.g. accounting or
taxation) will oblige the Administrator to process them;
b) We will keep your Personal Data longer in case you have any claims against the
Administrator, in order to assert claims by the Administrator, or in
in order to assert or defend against third party claims, for the period of their limitation
defined by law, in particular the Civil Code.
c) Depending on the scope of Personal Data and the purposes of their processing, they may therefore be
stored for different periods.
In any case, the longer period of storage of Personal Data will be decisive.
12. Will commercial information be sent to you (e.g. to your e-mail address)?
Administrator has a technical possibility to communicate with a Client remotely (e.g.
Commercial information related to the commercial activity conducted by the Administrator can
can be sent only on the basis of the consent given by the Customer, including acceptance of
Terms and Conditions of the newsletter service.
(a) To whom do “cookies” apply?
Due to the fact that the technology of cookies used by the Administrator (or with
functionality similar to cookies) collects information on each person visiting the Internet Shop
The following provisions of the Policy shall apply to persons who use the Internet Store
Internet Shop, regardless of whether they remain its Clients (place Orders, reserve Products or have an
or have an Account) (hereinafter also referred to as “Visitor”).
b) What technology do we use?
The Internet Shop uses technology which stores and accesses
information on a computer or other device connected to the network (in particular with
using cookies or related solutions) in order to provide maximum comfort while
comfort during the use of the Internet Shop, including for statistical purposes and for
adjust advertising content presented to the Visitor’s interests
Administrator, its partners and advertisers. During a visit to the Internet Shop, the following data may be collected
automatically collect data on the Visitor’s online activities.
Due to the fact that the Administrator may use solutions with functionality similar to
As the Administrator may use solutions with functionality similar to cookies – the following provisions of the Policy should also refer to these technologies accordingly.
c) What are “cookies”?
A cookie is a small piece of text information that is sent by a web server and stored on the Visitor’s
Visitor’s device (usually on the hard drive of a computer or mobile device).
device). It stores information that the Online Store may need to
to adapt to the Visitor’s usage patterns and to collect statistical data about the Online Shop and
The Visitor will not be able to use the Website for any purpose other than for the purpose of collecting statistics about the Website and the domain name of the Internet service provider or the country of origin of the Visitor.
the domain name of the Internet Service Provider or the country of origin of the Visitor.
d) Do cookies collect your personal data?
When a Visitor uses the App Store, cookies are used
that allow identification of his/her browser or device – cookies collect various types of
information that, in principle, do not constitute personal data (they do not allow the identification of the
Visitor). Some information, depending on its content and use,
However, some information may be associated with a specific person – the attribution of certain behaviour to a specific
Visitor, e.g. by linking it to the data provided when registering an Account with the
Online Shop – and thus be considered personal data.
In relation to information collected by cookies which can be linked to a specific person, the provisions of the
In relation to the information collected by cookies which can be linked to a specific person, the provisions of the Policy relating to Personal Data shall apply, in particular
in particular with regard to the rights of the data subject. Information regarding information collected
cookies is also made available, inter alia, in the information clause placed in a visible and easily
visible and easily accessible place during the first visit in the Internet Shop.
e) On what legal basis do we use “cookies”?
the consent of the Visitor. Normally, web browsers or other
software installed on your computer or other networked device
By default, web browsers or other software installed on a computer or other network-connected device will allow cookies to be placed on that device and thereby collect
information about Visitors. In the settings of your web browser or in the
technology, can be modified or revoked at any time (but some parts of the Store
store may not function properly). The withdrawal of consent does not affect the legality
of the processing that was done on the basis of consent before its withdrawal (detailed information on the
as to how to withdraw consent has been presented in the subsequent sections of this Policy).
The basis for the processing of such data is the Administrator’s legitimate interest, which is
the need to ensure the highest quality of content presented by the Administrator by
The basis for processing the data obtained in this way is the Administrator’s legitimate interest in ensuring the highest quality of the content presented by the Administrator by tailoring it to the Visitors’ preferences and marketing – including direct marketing – of the Administrator’s or his
products and services of the Administrator or its partners, in which case the partners do not participate in
processing of Customer data. On the other hand, to the extent that also partners of the Administrator
may have direct access to this information – the legal basis for such processing is
Customer’s freely given consent.
The cookies we use are primarily intended to make it easier for the Visitor to use the Online Shop
Online Shop and Application, for example, by “remembering” the information given once so that the Visitor does not
The purpose of the advertisements is to allow the user to select the content of the advertisements, including the advertisements presented to the user.
content, including the advertisements presented, to your preferences. Cookies are also used to increase the usability and
personalisation of the content of the Internet Shop, including the presentation, creation, granting and
the implementation of advertisements, offers or promotions (discounts) dedicated to a given Visitor in accordance with
interests (applies only if the Visitor is of full legal age and has given his/her consent to such
By means of technology of cookies used in the Internet Shop it is possible
The Administrator learns about the Visitor’s preferences, for example by analysing
how often the Visitor visits the Online Shop and whether and what products he or she buys in stationary stores belonging to
eobuwie.pl’s stationary stores. Analyzing online behavior helps to better understand
Visitors’ habits and expectations and to adapt to their needs and interests.
This technology makes it possible to present Visitors with advertisements tailored
to their needs and interests (for example, an advertisement resulting from recent viewing of
shoes only) and to prepare for Visitors of legal age who have
who have agreed to it, better promotions and surprises.
Based on cookies, the Administrator also uses technology that allows it to reach
advertising message to Visitors who have previously visited the Online Shop,
when they use other websites
g)Can you object to the use of information from cookies?
The Visitor can object to the actions of the Administrator taken for the purpose
described above. If the Visitor consents, including to
the presentation, creation, allocation and execution of dedicated advertising, offers or promotions
(discounts) tailored to their preferences, this consent may be withdrawn at any time – but this will not
However, this will not affect the legality of the processing that was carried out on the basis of consent
prior to its withdrawal.
14. how can you contact us?
At any time you can contact the Administrator by sending a message by post
or by e-mail to the address of the Administrator indicated at the beginning of the Policy or by phone at the
phone number indicated at the beginning of the Policy, as well as through Facebook.
If the Administrator is contacted in order to perform a specific action (e.g. submit a
When contacting the Administrator to perform a specific action (e.g. filing a complaint using the form), the Administrator may again request the person to
provide data, including personal data, e.g. name, surname, e-mail address, etc., in order to
confirm the person’s identity and enable the person to be contacted back on the matter and to perform the requested action.
requested action. Providing such data is not mandatory, but may be necessary to.
15. how do we secure your data?
The controller taking into account the state of the art, the cost of implementation and the nature, scope,
context and purposes of processing and the risk of violation of rights or freedoms of natural persons with different
probability of occurrence and the gravity of the threat, applies appropriate technical and
organisational measures to ensure the protection of the processed Personal Data appropriate to the risks
and categories of data protected, and in particular secures the data against
access to the data by unauthorized persons, its acquisition by an unauthorized person, processing in violation of the
in violation of applicable regulations, as well as against change, loss, damage or destruction.
Disclosing information to the outside world about the technical and organizational measures applied
ensuring the protection of processing may undermine their effectiveness and thus pose a threat to the proper
protection of Personal Data.
For example, the Administrator adequately provides the following technical measures to prevent
acquisition and modification by unauthorized persons of Personal Data sent via
Securing the data set against unauthorized access:
(a) SSL Certificate on the pages of the Online Store where Personal Data is provided.
b) Access to the Account only after providing an individual login and password.
16. May this policy be changed, and how will you find out about it?
The Administrator may change the Policy in the future for the following important reasons, among others:
(a) changes in applicable regulations, in particular in the area of Personal Data protection, telecommunications law
telecommunication law, law on services provided by electronic means, and law regulating the rights of
consumers, affecting the rights and obligations of the Administrator or the rights and obligations of the data subject
b) development of functionalities or Electronic Services dictated by the progress of Internet technology
Internet technology, including the use/implementation of new technological or technical solutions,
affecting the scope of the Policy.
17. when is this version of the Policy effective?
This version of the Policy is effective as of 25.05.2018.