Privacy policy

§1 GENERAL PROVISIONS

1. The Controller of personal data of Users provided to the Controller voluntarily as part of the provision of services by electronic means in the form of Account at the Website or in other circumstances set forth in the Regulations shall be L4D Sp. z o.o. (limited liability company) in the process of formation, with its registered office in Kamionka (hereinafter referred to as the “Controller”), email: administrator@look4dog.com.

2. Any capitalised words and acronyms used in this Policy (e.g. Controller, Account, Website, User) shall be understood in accordance with their definitions included in the Website Regulations available at: https://www.look4dog.com/en_gb/terms-and-conditions.

3. Personal data of Website Users shall be processed in accordance with the Regulation of the European Parliament and of the Council (EU) No. 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as “GDPR”), national legislation on the protection of personal data and the Act on the Provision of Services by Electronic Means of 18 July 2002 (Dz.U. [Journal of Laws] 2017, item 1219, uniform text, as amended).

4. The Controller exercises particular care in protecting the interests of data subjects, and particularly warrants that the collected data shall be processed in accordance with the law, collected for the specified legitimate purposes and not subject to further processing contrary to those purposes, correct in merit and adequate to the purposes for which they are processed, and stored in the form preventing the identification of data subjects for not longer than a period necessary to achieve the purpose of processing.

5. It is possible to visit the Website without providing personal data. The provision of personal data is voluntary, but may be necessary to set up an Account, make contact, enter into a contract or for any other purpose to which the data subject consents.

6. The Controller announces that it has not appointed Data Protection Officer (DPO) and independently performs the obligations related to the processing of personal data at the email address: administrator@look4dog.com.

§2 PURPOSE, SCOPE AND LEGAL BASIS OF DATA COLLECTION

1. The Controller shall collect personal data for the purposes of:

   1. establishment, formation of contents, change, performance or termination of the contractual relation between the Controller and the User which involves the provision of Services by electronic means,

   2. direct marketing of the Controller’s own products or services,

   3. in the case of Users who use the paid Services provided by the Controller, the personal data collected by the Controller shall be processed within the scope necessary to complete the payments. The payment system operator has their own, not less restrictive, principles on personal data protection.

2. The Controller shall process the following personal data of the Users: IP, first name and last name, electronic mail address, phone number, place of residence (street, building number, flat number, postal code, city, country), localisation data with marking placed on the map by the User. In the case of Users who are not private natural persons (hereinafter referred to as consumers), the Controller may additionally process the name of the company and the tax identification number (Polish abbreviation: NIP).

3. The provision of personal data referred to in section 2 of this article shall be voluntary, but some of the data may be necessary for the provision of Services by the Controller as part of the Website, for the completion of payment and issuance of invoice. Non-provision of required data before the commencement of provision of specific Services or the conclusion of the contract shall lead to the refusal to provide the Service and conclude the Contract due to the impossibility of its execution. The User shall be informed about the scope of required data before every commencement of provision of a given Service or conclusion of a given Contract.

4. The personal data of the User shall be processed on the basis of consent or necessity to execute the Contract to which the User is a party or to undertake actions at their request before or after its conclusion, as well as direct marketing for the Controller’s own products or services, or legitimate interest of the Controller.

5. Personal data provided by the Users shall not be made available to entities other than those that have a relevant legal basis, including on the basis of contracts for the processing of data in a manner not less restrictive than the Data Controller. In particular, personal data shall be made available in accordance with the principles set forth in § 7 below.

§ 3 USAGE DATA

1. With the use of proper software, the Controller may process the following data characterising the manner of using the Services by the User (usage data):

   1. Marks identifying the terminal of ICT network or ICT system the User has used;

   2. Information about the start, end and scope of the User’s each use of the service provided by electronic means;

   3. Information about the fact that the User has used the service provided by electronic means.

2. The usage data are collective and anonymous, that is they do not include features identifying the persons visiting the Website and are not made available to third parties.

§ 4 RIGHT TO CONTROL, ACCESS AND RECTIFY DATA

1. The User has the right to access the contents of their data and the right to rectify and erase them, restrict their processing, data portability, right to object to processing, right to withdraw their consent at any time, and such withdrawal shall not affect the legal compliance of the processing performed on the basis of such consent prior to the withdrawal. Every one of these rights and their application in a given situation shall depend on the basis of processing.

2. Every person shall have the right to control the processing of data included in the collection of data of the Controller which pertain to them, and particularly the right to request completion, update, clarification of personal data, temporary or permanent suspension of processing or their erasure, especially if they are incomplete, outdated, false or have been collected with the violation of the act or are irrelevant for the completion of purpose for which they have been collected. The right to suspend or erase and its application in a given situation shall depend on the basis of processing.

3. In the event of processing data for the purposes of direct marketing of own products or services of the Controller, the data subject shall also have the right to submit written request for the cessation of processing of their data and to lodge an objection against the processing of their data.

4. In order to exercise the rights referred to above, one may send a relevant request via an electronic mail message to the following address: administrator@look4dog.com, or in writing to the address of the registered office of the Controller.

5. Every person has the right to lodge a complaint with the President of the Personal Data Protection Office if they believe that their personal data are processed in violation of the provisions of the law, including the General Data Protection Regulation of 27 April 2016.

6. Personal data shall not be transferred to any third country/ international organisation.

7. Personal data shall be stored for a period necessary to execute the Contract, assert claims, but not longer than for a period required by specific provisions of the law, including the provisions of the law on accounting. Data processed on the basis of consent shall be stored until the withdrawal of the consent or deletion of the account from the website, if there is no other basis for their processing. This is specified in detail in the information clause (provide a link).

8. The data shall be processed by the Controller in an automated way, also in the form of profiling. However, it needs to be remembered that the Partners cooperating with the Controller, as indicated in § 5 of this Policy, shall process the data collected via the Website in order to display advertising based on the Users’ interests. Such data shall particularly include: IP (Internet Protocol) address, geolocalisation data derived from the User’s IP address, mobile advertising ID (MAID) (which allows the mobile app programmers to determine who uses their mobile apps), mobile app ID, type of browser, browser language, type of operating system, date and time when the User visited the website, behaviour on the website, such as time of browsing the Controller’s website by the User, User’s behaviour in relation to the contents on the Controller’s website, contents made available by them and interests shown by them, relevant URL and modes of searching in the network used by the User to localise and visit the Controller’s website, information about the User’s use of tools offered by the Partners and made available at the Controller’s website (for searching specific contents at the Controller’s website or making contents available). These data allow for the creation of marketing profiles of recipients of advertising and the analysis of website functionalities to adapt it to the preferences of Users.

9. The data specified in section 8 shall be collected with the use of cookies. The information about the use of cookies and about the possibility to manage cookies, also to block their use, shall be discussed in § 5 of this Policy.

§ 5 USE OF COOKIES

1. Cookies are small text and numerical files placed on the User’s computer when visiting the Website. Cookies enable Internet websites to recognise the User’s computer. In most cases, those files do not enable the identification of the User’s identity on the Internet. Cookies do not cause any damage at the User’s computer and do not contain viruses.

2. There are two commonly used types of cookies, session and persistent cookies. Session cookies are temporary files which stay on the User’s device until they log out from the website or close the browser. Persistent cookies stay in the memory of the User’s device for a period of time specified in their parameters or until they are manually deleted.

3. The Controller may use own cookies particularly in order to properly configure the website, perform processes necessary to use its full functionalities, authenticate the User at the Website and ensure the continuity of the User’s session at the Website, remember the location of the User, for the purposes of analyses, research, audit of views, and provision of advertising services.

4. The Controller may use third-party cookies, particularly within the scope of use of analytical tools, provision of advertising services, also for the purposes of identification of Users who share specific interests, which allows for the presentation of tailor-made advertisements, for enabling the provision of contents included in the Website at other websites, for enabling the registration and login to the Website with the use of data of the User’s account from other websites, and for enabling the completion of payment by the User for specific services provided by the Controller as a Service Provider.

5. The Controller shall use the following third-party cookies:

   1. Google technologies, including GoogleAdsense, in order to display context-related text advertisements, banners, video commercials via the Website (controller of third-party cookies: Google Inc, based in the USA) More: https://policies.google.com/privacy?hl=pl. Data generated by Google tools and technologies may be connected by the Google client, with the use of Google technologies, with cookies of other companies related to visits to other websites.

   2. Google Maps technology which allows for connecting locations with the User (controller of third-party cookies: Google Inc, based in the USA) More: https://policies.google.com/privacy?hl=pl.

   3.  in order to enable the User to make the payment for the Services provided via the Stripe or the Przelewy24 website (controller of third-party cookies: PayPro and DialCom24, based in Poznań). More: https://stripe.com/en-pl/privacy (Stripe) or https://www.przelewy24.pl/polityka-prywatnosci (Przelewy24).

6. If the User does not wish cookies to be used, they may manage the use of files at any time, also resign from this form of collecting data, in the following manner:

   1. By changing the settings of the Internet browser where, in the security settings, one may independently allow or block temporary and persistent cookies. Detailed information about the possibility and manner of handling cookies is available in the Help tab in the menu of any browser.

   2. By visiting websites indicated in section 5 to resign from the use of third-party cookies, including cookies allowing for the display of advertisements based on interests (if the provider or advertising network offer such possibility).

   3. With the use of dedicated tools for handling consumer choices to manage cookies used to display advertisements based on the Users’ interests. Such tools are available, for example, here: http://www.youronlinechoices.eu/ or here: http://www.aboutads.info/choices/ .

   4. If cookies are disabled, with the use of methods specified in this section, it is possible that some functionalities of our website shall be unavailable and some websites shall not be properly displayed. Without explicit consent of the User, we shall not match data.

§ 6 LOGIN VIA SOCIAL MEDIA (SOCIAL LOGIN)

1. The Controller offers the possibility to register and log in to the Website via one’s account on Facebook, Google+ or Twitter (social login). In such case it is not necessary to additionally register in order to set up a User Account at the Website. The User Account in social media, that is Google+, Facebook or Twitter, shall be associated with the Website User Account, which shall make it possible to authenticate and log in to the Client’s User Account via the social media User Account. The User does not have to remember a new password for the User Account. Thanks to the above-mentioned association, Facebook Inc., Twitter Inc. or Google Inc. shall automatically transfer the following information:

   1. numeric identifier of the social media (ID)

   2. full name

   3. sex

   4. user name in Twitter, Google+ or Facebook

   5. information whether the account has been verified, e.g. “yes”

   6. link to the public profile in the selected social media.

2. Pursuant to Article 6 section 1 letter a) of GDPR, the legal basis for the processing of data in relation to the use of optional login via social media (social login) shall be the consent presented below. In the event of using the Social Login Services, the user gives their consent to the processing of data, as presented below:

   1. I hereby give my consent to the transfer of the following data by the provider of my social media website (Twitter, Facebook or Google+) to the Controller as part of login via social media (social login):

      1. numeric identifier of the social media (ID)

      2. full name

      3. sex

      4. user name in Twitter, Google+ or Facebook

      5. information whether the account has been verified, e.g. “yes”

   2. I hereby allow the Controller to store such data and use them only for the purposes of logging in or addressing me in the User Account. I acknowledge that the use of login via social media (social login) shall automatically cause that the social media operator shall gain knowledge about the fact that a User Account has been created at the Website and is associated with my social media account.

   3. The consent may be withdrawn at any time, effective for the future, by sending a message to the email address: administrator@look4dog.com. In such case they shall not be able to use the social login function and the user shall have to normally register so as to set up the User Account. All data shall be stored until the consent is withdrawn.

More information about login to such websites as Twitter, Facebook and/or Google+ and privacy settings at the social media account can be found in the privacy policies and terms and conditions of use of Facebook, Twitter or Google+.

§7 DATA RECIPIENTS

1. For the Website to operate properly, it is necessary that the Controller should use the services of third-party entities (such as, for example, software supplier, courier or payment handling entity). The Controller uses only the services of such processing entities that provide sufficient guarantees of implementing relevant technical and organisational measures so that the processing would be compliant with the GDPR and protect the rights of data subjects.

2. The data shall not be transferred by the Controller in every case and to all recipients or categories of recipients listed in the privacy policy. The Controller shall transfer data only when it is necessary to achieve a given purpose of personal data processing and only within the scope necessary for its achievement.

3. Personal data of Users may be transferred to the following recipients or categories of recipients:

   1. carriers/ forwarders/ courier brokers – in the case of User who uses the delivery method in the Website that involves shipping by post or courier services, the Controller shall provide the collected personal data of the User to a selected carrier, forwarder or agent performing shipments upon the order of the Controller within the scope necessary to complete the delivery to the User.

   2. Entities handling electronic or card payments – in the case of User who uses the electronic or card payment method in the Website, the Controller shall provide the collected personal data of the User to a selected entity handling the above-mentioned payments at the Website upon the order of the Controller within the scope necessary to handle the payment made by the User.

   3. Opinion survey system provider – in the case of User who agrees to giving their opinion about the Website and services provided therein, the Controller shall provide the collected personal data of the User to a selected entity providing the opinion survey system upon the order of the Controller within the scope necessary for the User to express their opinion with the help of opinion survey system.

   4. Controller’s service providers with regard to technical, IT and organisational solutions that enable the Controller to run business activities, including the Website and electronic services provided therein (in particular providers of computer software for running the Website, electronic mail and hosting providers, and providers of software for company management and technical support for the Controller) – the Controller shall provide the collected personal data of the User to a selected provider acting upon the order of the Controller only in the case and within the scope necessary to achieve a given purpose of data processing consistent with this privacy policy.

   5. Controller’s service provider with regard to accounting, legal and consulting services (in particular the accounting office, law office or debt collection company) – the Controller shall provide the collected personal data of the User to a selected provider acting upon the order of the Controller only in the case and within the scope necessary to achieve a given purpose of data processing consistent with this privacy policy.

   6. Provider of social media add-ons, scripts and similar tools embedded at the Website that allow the browser of the Website visitor to download the contents from the providers of such add-ons (e.g. login with social media login details) and to transfer personal data of the visitor for this purpose to such providers, including: 

- Facebook Ireland Ltd. – the Controller uses the Facebook social media add-ons at the Online Shop website, and thus gathers and makes personal data of the User using the Website available to Facebook Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland) within the scope and in accordance with the privacy principles set forth here: https://www.facebook.com/about/privacy/ (these data include information on actions at the Website, including information about the device, visited websites, purchases, displayed ads and manner of using the services, regardless of the fact whether the User has a Facebook account or is logged in to Facebook).

§ 8 FINAL PROVISIONS

1. The Website may contain links to other websites. The Controller recommends that, after going to other websites, one should read the privacy policy presented there. This Privacy Policy only applies to the Website and the Controller’s website.

2. The Controller employs technical and organisational means allowing for the protection of the processed personal data adequate to threats and categories of data subject to protection, and particularly secures the data against making them available to unauthorised persons, being taken by an unauthorised person, processing them with the violation of applicable provisions of the law, and changing, losing, damaging or destroying such data in accordance with the applicable provisions of the law.