Privacy Policy

This document sets forth the Privacy Policy of the www.sunew.pl Website (hereinafter referred to as the “Website”).
Words used with a capital letter have the meaning given to them in the terms and conditions of the www.sunew.pl Website.

Personal data collected by the Administrator of the Website are processed in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27.04.2016.
on the protection of natural persons with regard to the processing of personal data and on the free flow of such data and repealing Directive 95/46/EC (General Data Protection Regulation) (Dz.
Urz.
EU L 119,
s. 1), hereinafter referred to as the RODO.

The Administrator of the Website makes special efforts to protect privacy and information provided to him and concerning Website Users.
The Administrator shall exercise due diligence in the selection and use of appropriate technical measures, including those of a programming and organizational nature, to ensure the protection of the processed data, in particular to protect the data from being made available to unauthorized persons, disclosure, loss and destruction, unauthorized modification, as well as from being processed in violation of applicable laws.

The target of the opportunity to use the Services available on the website is not children under the age of 16.
The Data Controller does not provide for the purposeful collection of data on children under 16 years of age.

I. PERSONAL DATA CONTROLLER

1. The Administrator of the personal data is SUNEWMED+ POLAND Ltd. with its seat in Żerniki (62-023), ul.
   Przemysłowa 16, registered in the National Court Register by the District Court in Poznań, VIII Economic Department under the KRS number 0001114496, holding NIP: 7773354896 (hereinafter referred to as “Administrator”).
2. The Administrator can be contacted in writing at the address indicated in the paragraph above or by email at [email protected]

II.
DATA PROTECTION OFFICER If you have questions about our processing of your personal data and your rights, you can contact our Data Protection Officer: Rafal Surowy, via:

1. email: [email protected]
2. snail mail: SUNEWMED+ POLAND limited liability company 62-023 Żerniki, ul.
   Przemysłowa 16.

III.
PURPOSES AND LEGAL GROUNDS, AND PERIODS OF PROCESSING OF PERSONAL DATA

1. Conclusion and execution of the contract

In order to carry out activities related to the proper conclusion and performance of the contract, the legal basis for the processing of your personal data is Art.
6 para.
1.
Lit. b. RODO .
W związku z realizacją w/w celów, dane są przetwarzane w szczególności w ramach poniższych działań:

1. 1. related to the establishment of an account on the Sunew.pl Website In this case, the data provided in the registration form of the Website are processed, i.e.: name and surname, e-mail address, telephone number;
   2. necessary to properly place an order (conclude a contract) on the Sunew.pl Website In this case, the following data is processed: first and last name, e-mail address, telephone number, address(es) indicated for delivery of the order, billing data: first name, last name, tax ID, billing address;
   3. related to the proper execution of the contract.
      In this case, the following data are processed: name, address(es) indicated as appropriate for delivery of the order.

Provision of data is voluntary, however, it is necessary for the proper conclusion and implementation of the contract, the consequence of failure to provide data will be the inability to use the Administrator’s services.
Personal data will be processed:

1. 1. for purposes related to the creation of an account in the sunew.pl Internet Service – for a period of 30 days calculated from the 1st day of the month following the date of notification to the Data Administrator of the request to delete an account in the Internet Service, or after deletion of the account directly by the customer,
   2. for the purposes necessary for the proper placement of an order (conclusion of a contract) on the sunew.pl Internet Service.
      – for a period of 30 days counted from the 1st day of the month following the date of notification to the Data Administrator of the request to delete the account on the Website, or after the account is deleted directly by the customer,
   3. for purposes related to the proper execution of the contract – for a period of 30 days calculated from the 1st day of the month following the date of notification to the Data Controller of the request to delete the account on the Website, or after deletion of the account directly by the customer.

2. Archiving of data after contract/service completion

In order to carry out the obligations incumbent on the data controller and arising from applicable laws, including in particular obligations related to the implementation of tax regulations, the legal basis for the processing of your data is Art.
6.
Para.
1.
Lit. c RODO .
Dane osobowe będziemy przetwarzali przez okresy wynikające z obowiązujących przepisów prawa, jednakże nie krócej niż przez okres 5-ciu lat, liczonych od dnia 1 stycznia następującego po dacie ostatniego zdarzenia gospodarczego związanego z danym klientem.  

3. Email newsletter and sms newsletter service

With regard to the implementation of Newsletter services, your data are processed on the basis of your consent, the legal basis for data processing is Art.
6 para.
1 lit. a RODO , to the extent necessary for the proper implementation of this service, the legal basis for data processing is Art.
6 para.
1(b) RODO , and in the legitimate interest pursued by the controller, the legal basis for the processing is Art.
6 para.
1(f) RODO. In connection with the implementation of the service, the following data are processed:

1. e-mail address (Newsletter E-MAIL),

Provision of personal data is voluntary, but necessary to subscribe and use the Newsletter service, the consequence of failure to provide data will be the inability to use the service.
Personal data used in the provision of the Newsletter service will be processed until the service user unsubscribes – in accordance with the terms and conditions of the Newsletter service.

4. Social media

With regard to activities carried out through social media, we will process your data for the following purposes:

1. to maintain our profile/channel on social media, under the terms and conditions stipulated by them, and to inform you through them about our activities, events organized by us and products and services offered,
2. contact/interaction with you conducted, via profile/channel functionality,
3. Analysis of the functioning, popularity and usage of our profile/channel,
4. sending commercial information, including invitations to events organized by us, through profile/channel functionality.

The legal basis for the processing of your data for the purposes mentioned above is the legitimate interest, i.e. Art.
6 para.
1.
Lit. f RODO , which is to promote our activities and expand our circle of supporters and answer your questions.
We process your personal data for the period of your activity related to our profile/channel, and then at most until you delete your social media account, or remove your data from our profile/channel.

5. Other activities carried out by the Data Controller,

In connection with the performance of other tasks, we may process your data in particular for the following purposes and scopes:

1. 1. for the establishment, investigation and enforcement of claims and defense against claims in legal proceedings or before other enforcement authorities, data necessary to prove the existence of a claim or data that arises from a legal requirement, court order or other legal procedure may be processed.

The data used in the implementation of the above purposes, are processed until the cessation/satisfaction of claims, however, no longer than until the statute of limitations for possible claims specified by law.
The legal basis for processing is respectively: Art.
6 para.
1(c) and art.
6 para.
1.
Lit. f RODO ;

1. 2. in order to process complaints, complaints and requests, and to respond to inquiries, we process personal data that you have provided in the contact form or given to our consultant during a phone call.

The legal basis for the processing of data within the framework of the complaint procedure, the handling of complaints and requests, within the framework of answering questions in another form as well as the processing of data contained in documents attached to complaints, complaints or requests, respectively, are: Art.
6 para.
1 lit. a and Art.
6 para.
1(f) RODO;

1. 3. for the purpose of marketing our own products and services, we may process personal data provided by you when you set up an Account and/or update your Account on the sunew.pl Website.

The legal basis for processing is respectively: Art.
6 para.
1 lit. c and art.
6(1)(f) RODO ;

1. 4. for the purpose of organizing contests, the personal data provided by the user in the Account and/or the personal data provided during the application for participation/registration in the contest are processed.
      Detailed information about the processing of personal data and the legal grounds related to the processing of contest participants’ data are provided each time in the regulations of the respective contest.
   5. in order to present our marketing messages distributed outside the Website, we use the services of third-party providers.
      These services consist in displaying our marketing messages on websites other than the sunew.co.uk Website, which messages are distributed by the providers on a remarketing basis.
      For details on the processing of personal data described in this section, please refer to the cookie records.
      The legal basis for the processing is Art.
      6 para.
      1 lit. a and art.
      6(1)(f) RODO ;
   6. for the purpose of market and opinion research by us or our partners, the data indicated by the user in the Account within the sunew.pl website is processed, including in particular – email address, telephone, address data (city/postal code).
      Data processed as part of market research and opinion surveys are not used by us for other purposes including advertising.
      Precise information regarding the processing of personal data is indicated each time in a given survey or in the place where the user enters his/her data to participate in a given survey.

The legal basis for data processing is Art.
6 para.
1(f) RODO . IV.
CATEGORIES OF PERSONAL DATA The Administrator processes the following categories of personal data:

1. contact data, including order data – (customers, users of the Website)
2. Activity data on the Website – (customers, users of the Website),
3. Data on complaints of complaints and requests – (customers, users of the Website),
4. Data on marketing services, (customers, users of the Website or partner systems),

V. RIGHTS OF PERSONS IN CONNECTION WITH THE PROCESSING OF THEIR PERSONAL DATA Each person whose data is processed by the Controller has the following rights:

1. The right to access the content of your data,
2. The right to rectify your data,
3. The right to delete your data if:
   1. consent to the processing of personal data is withdrawn,
   2. personal data will no longer be necessary for the purposes for which they were collected or for which they were processed,
   3. an objection is made to the use of data for marketing purposes,
   4. an objection is raised to the use of data for the purpose of customizing the Administrator’s services to the data subject’s preferences,
   5. Personal data is processed illegally,
4. The right to restrict data processing,
5. The right to object to data processing,
6. The right to data portability,
7. The right to withdraw consent at any time, whereby withdrawal of consent does not affect data processing performed by the Administrator prior to its withdrawal.

In addition, each person also has the right to lodge a complaint with the supervisory authority (PUODO) if the person believes that the processing of his/her personal data by the Administrator violates the provisions of the applicable law. VI.
TAILORING THE SERVICE TO USERS’ INTERESTS AND PREFERENCES Based on the data, obtained from the users of our sunew.pl Website, we match the content of online advertisements to their preferences.
The legal basis for these activities is Art.
6.
Para.
1 lit. f RODO , i.e.
Legally justified interest, which consists in promoting our services and products and selecting the best possible offer for our customers.
The scope of data that we collect in the course of tailoring our services to the interests and preferences of our users can be set or changed by the user by – accepting the cookie policy, or by modifying the settings of the Internet browser used, for example by disabling personalization of advertisements.
In this regard, we refer you to the relevant terms and conditions and settings of the browser you are using, and to our cookie policy. VII.
SHARING OF PERSONAL DATA As a Data Controller, we use companies to support us in providing the highest standard of service to our customers.
To these companies we may outsource/trust the processing of your data on our behalf and for our benefit.
The transfer of data usually occurs when we cooperate with a specific service provider (e.g., data storage service provider, provider of tools used in the framework of Internet communication) or subcontractor (e.g., logistics service provider, marketing agency, etc.).
In such a situation, the transfer of data does not entitle other entities to process the data arbitrarily, but only to use it for the purposes expressly indicated by us.
In any case, the transfer of data does not relieve us, as a Personal Data Controller, of responsibility for their processing.
Your data may also be transferred to public authorities, but only when authorized by applicable laws.
In connection with our use of social media, your personal data may be transferred to the owners of the following portals: among others.
Facebook, Instagram, as well as marketing agencies that serve us.
Our service providers are primarily based in Poland and other countries in the European Economic Area (EEA).
Some of the providers are based outside the EEA.
In connection with the transfer of your data outside the EEA, including to the USA, we have ensured that our providers provide, as part of the services they provide, a guarantee of a high level of protection for your personal data.  

COOKIE POLICY

This Policy applies to “cookies” and applies to websites operated by Sunewmed+ Sp.
z o.o. with headquarters in Żerniki (62-023), ul.
Przemysłowa 16.
By “cookies” we mean IT data, in particular text files, stored in users’ terminal equipment, intended for use on websites.
These files allow to recognize the user’s device and appropriately display the website tailored to his individual preferences.
“Cookies” usually contain the name of the website from which they come, the time they are stored on the end device and a unique number. We use “cookies” for the following purposes:

1. adapting the content of the Website’s pages to the User’s preferences and to optimizing the use of the Website’s content; in particular, these files allow for the recognition of the Website User’s device and appropriate display of the website, adjusted according to his/her individual needs,
2. creation of statistics that help to understand how the Users of the Website use the websites provided, which enables us to improve their structure and content,
3. Maintaining the session of the User of the Website (after logging in), thanks to which the User does not have to re-enter his/her login and password on each sub-page of the Website,

What kind of “cookies” do we use?

1. The Website uses two main types of cookies:
   1. “session” (session cookies) – these are temporary files that are stored on the User’s terminal device until the User logs out, leaves the website or shuts down the software (web browser).
   2. “permanent” (persistent cookies) – these are files stored on the User’s terminal device for the time specified in the parameters of the cookie data or until they are deleted by the User.
2. The websites use the following types of cookies:
   1. “indispensable” cookies that enable the use of services available on the websites, such as authentication cookies used for services that require authentication on the websites,
   2. cookies for security purposes, such as those used to detect misuse of website authentication,
   3. “performance” cookies, which allow you to collect information about how you use the websites,
   4. “functional” cookies, which allow “remembering” the User’s chosen settings and personalizing the User’s interface, e.g. with regard to the chosen language or region of origin of the User, font size, appearance of the website, etc,
   5. “advertising” cookies, allowing to provide Users with advertising content more tailored to their interests,
   6. “Analytical” web analytics cookies allow us to better understand how users interact with web content in order to better organize the layout of our site.
      They collect information about how visitors use our site, the type of site from which users were redirected, and the number of visits and the length of time users visited the site.
      This information does not record specific personal information about the user, but is used to compile statistics on the use of the site at an aggregate level.
      For this purpose, we use the Google Analytics solution.

Cookies of independent companies located on the Operator’s websites:

1. Google Analytics, web analytics cookies collect information about how visitors use our site, the type of site from which users were redirected, and the number of times users visited and the length of their visit to that site.
   This information does not record specific personal information about the user, but is used to compile statistics on the use of the site on an aggregate basis.

For more information on these cookies, please visit: https://tools.google.com.

2. Meta Platforms Ireland Limited (Facebook), the website uses cookies that record the browser id and an encrypted version of the identity of the User logged into Facebook.
   These files allow us to analyze the number of visits by Users redirected to the Operator’s website from links published on Facebook and to tailor communications and offers to the needs of visitors.

For more information, visit: https://www.facebook.com/policies/cookies/.

3. Pinterest – the website uses cookies that record the browser id and an encrypted version of the identity of the User logged into Pinterest.
   These files allow us to analyze the number of visits of Users redirected to the Operator’s website from links published on Pinterest to customize communication and offerings to the needs of visitors.
   For more information, please visit: https://pl.pinterest.com/.
4. Amazon – the site uses cookies that collect information about what products a visitor has visited and the contents of the shopping cart.
   These cookies are used to increase the site’s conversion rate through targeted advertising and product promotions via email, in addition, the cookies record information about the actions the user performed during the current visit to the site, including searches with keywords.
   For more information, visit: https://www.amazon.com/gp/help/customer/display.html?
5. Edrone – cookies optimize the promotion of products on the site by collecting information about what products or events a user has seen and then promoting related products and events.
   For more information, visit: https://edrone.me/privacy-policy
6. TIKTOK – cookies used by the TikTok social network to track the use of embedded services.
   For more information, visit: https://www.tiktok.com/legal/page/eea/privacy-policy/en
7. SMARTLOOK – cookies collect statistical data related to a user’s visit to the site, such as the number of visits, average time spent on the site, and what pages were loaded.
   The goal is to segment site users by factors such as demographics and geographic location to allow media and marketing agencies to sort and understand target groups, and target individualized online advertising.
   For more information, visit: https://help.smartlook.com/docs/privacy-policy

Legal basis for processing: The legal basis for processing personal data via cookies are:

1. consent given by the user (art.
   6(1)(a) RODO ) – by making individual preferences settings for the use of cookies by the user’s browser ,
2. performance of the contract or for the purpose of taking action prior to the conclusion of the contract (Art.
   6(1)(b) RODO) – in order to maintain the user’s session, transfer the order, coordinate the payment process, etc.
3. Excusable purpose of the data controller(Article 6(1)(f) RODO) – collection of statistical information, optimization of site customization, etc.

Do “cookies” contain personal information? Personal data collected using “cookies” may be collected only for the purpose of performing certain functions for the user.
Such data are encrypted in a way that prevents unauthorized access. How long will we process cookies? If the User consents to the storage of cookies, they will be processed/stored for a maximum of 365 days from the date of consent to their storage.
After this period, during the User’s next visit, the User will be asked to consent to their storage again. Deletion of “cookies” By default, web browsing software allows the placement of “cookies” on the end device.
These settings can be changed in such a way as to block the automatic handling of “cookies” in the settings of your web browser or inform you each time they are sent to your device.
Detailed information about the possibility and methods of handling “cookies” is available in the settings of your software (web browser).

1. Internet Explorer (https://support.microsoft.com/pl-pl/help/17441/windows-internet-explorer-change-reset-settings)
2. FireFox (https://support.mozilla.org/pl/kb/firefox-opcje-preferencje-i-ustawienia)
3. Opera (https://help.opera.com/pl/touch/settings/)
4. Chrome (https://support.google.com/accounts/answer/3118621?hl=pl)

Restricting the use of cookies may affect some of the functionality available on the website. What security features are used on the sites? The Operator’s websites are provided with security measures to protect the data under its control from loss, misuse or modification.
The Operator undertakes to protect any information disclosed to it by Customers in accordance with standards of security protection and confidentiality.
The Website Operator provides Users with the option to opt-out of receiving advertising materials and ordered newsletters.
The Operator provides Users with the option to remove information about themselves from databases and allows them to stop receiving information sent via electronic letters.  

1. The Administrator informs Users that it entrusts the processing of personal data to the following entities: – Edrone Sp.
   z o.o., ul.
   Lekarska 1, 31-203 Kraków, NIP: 676-248-20-64, KRS: 0000537197 – in order to use the edrone.me mailing system for sending newsletters, – Edrone Sp.
   z o.o., ul.
   Lekarska 1, 31-203 Kraków, NIP: 676-248-20-64, KRS: 0000537197: – for marketing purposes only for the purposes of emali, sms, social media campaigns launched or indicated by the Administrator using the edrone system.
2. The Administrator informs that it uses the following technologies to track the actions taken by the user/customer on the Store website: – edrone tracking codes – for the purpose of analyzing the statistics of the Store’s website, as well as for marketing purposes only for the purposes of e-mail, sms, social media campaigns launched or indicated by the Administrator using the edrone system.