Privacy and Cookies Policy

1.1. The administrator of your personal data is Blue Moon II Spółka z ograniczoną odpowiedzialnością with its registered office in Warsaw, ul. Stefana Okrzei 26/6, 03-710 Warszawa, entered into the National Court Register under KRS number: 0001069087, maintained by the District Court for the capital city of Warsaw in Warsaw, XIII Commercial Division of the National Court Register, NIP: 1133115435, REGON: 526940842. In case of any doubts related to the privacy policy, you can contact us at any time by sending a message to: ul. Stefana Okrzei 26/6, 03-710 Warszawa.

1.2. GDPR (Regulation (EU) 2016/679 of the European Parliament and of the Council 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) grants you the following rights related to the processing of your personal data:

1. the right to access your data and receive a copy of it,

2. the right to rectify (correct) your data,

3. the right to delete data (if in your opinion there are no grounds for us to process your data, you can request that we delete it),

4. the right to restrict data processing (you can request that data processing be restricted only to its storage or performing activities agreed with you),

5. the right to object to data processing (you have the right to object to data processing on the basis of a legitimate interest; you should indicate a specific situation that in your opinion justifies us stopping the processing covered by the objection. We will stop processing your data for these purposes unless we demonstrate that the grounds for processing override your rights or that your data is necessary for us to establish, exercise or defend claims),

6. the right to data portability (you have the right to receive from us in a structured, commonly used machine-readable format the personal data you provided to us on the basis of a contract or your consent; you can instruct us to send this data directly to another entity),

7. the right to lodge a complaint with a supervisory authority (if you find that we process data unlawfully, you can file a complaint with the President of the Personal Data Protection Office (UODO) or another appropriate supervisory authority).

The rules related to the implementation of the above rights are described in detail in Art. 16 – 21 GDPR. Remember that you can also request information from us about what data we have about you and for what purposes we process it. Just send a message to info@inkluz.com.

1.3. Your personal data may be processed by entities whose services we use. They may have access to your personal data if the services they provide involve or may involve personal data processing within the scope related to such access. This includes in particular entities such as the hosting provider, email service providers, the entity providing technical support services for the website, law firms, entities providing marketing services, accounting firms, cloud software providers, entities providing postal and courier services, etc. Remember that your data is safe and processed only to the necessary extent. Furthermore, if necessary, your personal data may be shared with entities, authorities, or institutions entitled to access data under the law, such as the police, security services, courts, prosecutors' offices, as well as tax offices to the extent necessary to perform tax, settlement, and accounting obligations.

1.4. We transfer your personal data to third countries in connection with the use of tools that store personal data on servers located in third countries, in particular the USA. The providers of these tools guarantee an adequate level of personal data protection through appropriate compliance mechanisms provided by GDPR or the use of standard contractual clauses. Storage of personal data on servers located in third countries occurs, among others, within (described in this privacy policy) Google services, provided by Google Ireland Limited, Facebook and Instagram, provided by Meta Platforms Inc.

1.5. We use tools that may take specific actions depending on the information collected within tracking mechanisms (profiling and behavioral advertising). However, we believe that these actions do not have a significant impact on you because they do not differentiate your situation as a customer and do not affect the terms of the contract you may conclude with us.

1.7 Comments.

We provide the possibility to add comments on our website thanks to the Disqus system. Use of this system is based on the Disqus terms of use, which you accept as its user. Within the Disqus system, we do not have access to your personal data, except for your nickname defined in the Disqus system and image, if available within your user account in the Disqus system. The provider of the Disqus system is an independent administrator of your personal data processed within the Disqus system.

2.1. Contact.

Processed data: name, email address plus optionally data contained in the message content (providing data is voluntary, but necessary to establish contact).

Purpose of processing: establishing contact.

Processing period: The content of correspondence may be subject to archiving and we are unable to clearly determine when it will be deleted.

Legal basis: Art. 6(1)(f) GDPR, i.e., our legitimate interest. The legal basis for processing after the contact has ended is also our justified purpose in the form of archiving correspondence for internal needs (Art. 6(1)(f) GDPR).

Rights: You have the right to request a history of the correspondence you have had with us (if it has been archived), as well as to request its deletion, unless its archiving is justified due to our overriding interests, e.g., defense against potential claims on your part.

2.2. Newsletter.

Processed data: name and email address (providing data is voluntary, but necessary to subscribe to the newsletter).

Purpose of processing: sending the newsletter. The mailing system we use tracks your actions related to the messages sent to you. Therefore, we have information about which messages you opened, within which messages you clicked on links, etc.

Processing period: the duration of the newsletter service, as well as for archiving purposes for the possibility of demonstrating the fact that you have given your consent to receive the newsletter in the past.

Legal basis: consent (Art. 6(1)(a) GDPR) expressed when signing up for the newsletter.

Rights: You can unsubscribe from the newsletter at any time by clicking on the dedicated link in every newsletter message or simply by contacting us. You can rectify your data or object to the processing of your personal data. Due to our legitimate interest (Art. 6(1)(f) GDPR), we will not delete your data from the database. Deleting such data would prevent us from demonstrating that you have given your consent to receive the newsletter in the past.

2.3. User account.

Processed data: email address and password (providing data is voluntary, but necessary to create an account. Within account data editing, you can provide further data).

Purpose of processing: providing you with an electronic service consisting of providing the possibility of using a user account.

Processing period: You can delete your account at any time. If you decide to do so, your data will still be stored in the database so that we can identify you as a returning user in the future, if you decide to use the site again as a registered user. In this regard, the legal basis for processing your personal data is our legally justified interest – Art. 6(1)(f) GDPR.

Legal basis: contract concluded on the terms described in the regulations - Art. 6(1)(b) GDPR.

2.4. Orders.

Processed data: data necessary to fulfill the order, i.e.: name and surname, billing address, company data, email address, phone number, NIP number. (Providing data is voluntary, but necessary to place an order).

Purpose of processing: execution of the contract concluded by placing an order, issuing an invoice and including it in accounting documentation, archival and statistical purposes, and direct marketing of own products and services.

Processing period: the time necessary to fulfill the order, and then until the limitation period for claims under the concluded contract expires.

After this period, the data may still be processed by us for archival or statistical purposes, e.g., to identify a returning customer, as well as for direct marketing purposes of our own products and services until an objection is raised.

Legal basis: execution of the contract concluded by placing an order (Art. 6(1)(b) GDPR), issuing an invoice (Art. 6(1)(c) GDPR), including the invoice in accounting documentation (Art. 6(1)(c) GDPR), direct marketing of our own products and services (Art. 6(1)(f) GDPR), and for archival and statistical purposes (Art. 6(1)(f) GDPR).

Rights: In the case of order data, you do not have the possibility to rectify this data after the order has been fulfilled. You also cannot object to the processing of data and demand the deletion of data until the limitation period for claims under the concluded contract expires. Similarly, you cannot object to data processing and demand the deletion of data contained in invoices. You can object to the processing of data for direct marketing purposes of products and services.

2.5. Abandoned cart recovery.

Processed data: email address.

Purpose of processing: possibility to finalize the order. (For this purpose, your personal data collected by us in connection with you starting to place an order is processed).

Processing period: You can object to the processing of your data for abandoned cart recovery purposes by clicking on the link available in the message sent as part of the abandoned cart recovery.

Legal basis: legitimate interest (Art. 6(1)(f) GDPR).

2.6. Complaints and withdrawal from the contract.

Processed data: name and surname, residential address, phone number, email address, bank account number. Providing data is voluntary, but necessary to submit a complaint or withdraw from the contract.

Purpose of processing: implementation of the complaint procedure or the contract withdrawal procedure.

Processing period: time necessary to implement the complaint procedure or the withdrawal procedure. Complaints and statements of withdrawal from the contract may also be archived for the possibility of demonstrating the course of the complaint or withdrawal process in the future.

Legal basis: for the purpose of implementing the complaint procedure or the contract withdrawal procedure (Art. 6(1)(c) GDPR), and then for archival purposes, which constitutes our legally justified interest (Art. 6(1)(f) GDPR).

Rights: In the case of data contained in complaints and statements of withdrawal from the contract, you do not have the possibility to rectify this data. You also cannot object to the processing of data and demand the deletion of data until the limitation period for claims under the concluded contract expires. After the limitation period for claims under the concluded contract, however, you can object to our processing of your data, as well as demand the deletion of your data from the database.

2.7. Comments/reviews.

Processed data: email address, nickname, content of the shared comment/review.

Purpose of processing: sharing a comment/review.

Processing period: comments/reviews are published for an indefinite period. They may also subsequently be subject to archiving and we are unable to clearly determine when they will be deleted.

Legal basis: Art. 6(1)(f) GDPR, i.e., our legitimate interest related to conducting direct marketing. The legal basis for processing after the comment/review is no longer shared is also our justified purpose in the form of archiving the comment/review for internal needs (Art. 6(1)(f) GDPR).

Rights: You have the right to request access to the comment/review you published (if it has been archived), as well as to request its deletion, unless its archiving is justified due to our overriding interests, e.g., defense against potential claims on your part.

2.8. Processing reports regarding user content.

Processed data: name and surname, address data, email address, content of the submitted report.

Purpose of processing: implementation of the procedure regarding notifications of illegal content, in accordance with the guidelines of the DSA (Digital Services Act).

Processing period: data is processed until the limitation period for claims under our liability as a hosting provider within the meaning of the DSA regulation expires. Notifications may also be archived for the purpose of possibly demonstrating the course of the process regarding illegal content.

Legal basis: Implementation of the procedure regarding the processing of notifications of illegal content is based on a legal obligation incumbent on the administrator; (Art. 6(1)(c) GDPR).

Rights: in the case of data contained in notifications of illegal content, you do not have the possibility to rectify this data. You also cannot object to data processing and demand the deletion of data until the limitation period for claims expires. After the limitation period for claims, however, you can object to our processing of your data, as well as demand the deletion of your data from the database - we will stop processing your data unless we demonstrate that the grounds for processing data override your rights.

2.9. User content storage.

Processed data: user content published through comments, reviews, or other functions enabling the publication of content on our site, user identification data (including email address, IP identifier, nickname).

Purpose of processing: enabling the publication of user content and its storage.

Storage period: data is processed until the user content is deleted. This content may also be archived for the purpose of possibly establishing, pursuing or defending claims related to the Content.

Legal basis: storage of user content is necessary for the performance of a contract (provision of services by electronic means) to which the data subject is a party, or to take action at the request of the data subject prior to entering into a contract; the legally justified interest of the data administrator in the scope of conducting online activities (Art. 6(1)(b) GDPR).

Rights: you have the right to request access to your data, and you also have the right to object to our processing of your data, as well as to demand the deletion of your data from the database - we will stop processing your data unless we demonstrate that the grounds for processing data override your rights.

3.1. Cookies and other tracking technologies. Our website uses cookies.

Cookies are small text information stored on your terminal device (e.g., computer, tablet, smartphone) that can be read by our IT system (first-party cookies) or the IT system of third parties (third-party cookies). Some cookies we use are deleted after the end of the web browser session, i.e., after it is closed (so-called session cookies). Other cookies are stored on your terminal device and allow us to recognize your browser upon your next visit to the site (persistent cookies).

3.2. Consent to cookies.

• During your first visit to the site, information about the use of cookies is displayed to you along with a question about consent to use these files. Thanks to a special tool, you have the possibility to manage cookies from within the site, disabling individual groups of cookies.
• You can always change cookie settings from your browser or delete cookies entirely. Browsers manage cookie settings in different ways. You will find explanations regarding changing cookie settings in the help menu of your web browser.
• You can also manage cookie settings by installing special add-ons that allow you to control cookies.
• Disabling or restricting the use of cookies may cause difficulties in using our site, as well as many other websites that use cookies.

3.3. Server logs.

• Using the site involves sending queries to the server where the site is stored. Every query directed to the server is recorded in the server logs.
• Logs include, among others, your IP address, server date and time, information about the web browser and operating system you are using.
• Logs are saved and stored on the server. Data recorded in the server logs are not associated with specific persons using the site and are not used by us to identify you.
• Server logs constitute strictly auxiliary material used to administer the site, and their content is not disclosed to anyone except persons authorized to administer the server.

3.4. Google Analytics.

• We use the Google Analytics tool provided by Google LLC based in the USA.
• The goal is to create statistics and analyze them in order to optimize our websites.
• Collected data are not personal data and do not allow for your identification. The information we have access to within Google Analytics includes, in particular: information about the operating system and web browser you use, the subpages you view within our website, the time spent on our website and its subpages, the source from which you come to our website.
• Within Google Analytics, we use Advertising Features such as demographic and interests reports, the age range you are in, gender, approximate location, interests determined based on online activity.
• In order to use Google Analytics, we have implemented a special Google Analytics tracking code in our site's code. The tracking code uses cookies from Google LLC regarding the Google Analytics service.

3.5. Google Ads.

• We use the Google Ads advertising program operated by Google LLC.
• The goal is to conduct advertising campaigns, including remarketing, and the basis is a legally justified interest consisting of marketing our own products or services.
• Collected data are not personal data and do not allow for your identification.
• Upon visiting our website, a remarketing cookie from Google is automatically left on your device, which, with the help of a pseudonymous identifier (ID) and based on the pages you visit, enables the display of interest-based ads.
• Further processing of information takes place only if you have given consent to Google to combine browsing history and app usage with your account and use information from your Google account to personalize the ads that are displayed on websites.
• If in such a case you are logged in during your visit to our website to a Google service, Google will use your data together with Google Analytics data to create and define lists of target groups for remarketing purposes across different devices. For this purpose, Google temporarily combines collected information with Google Analytics data to create target groups.
• In order to use Google Ads, we have implemented a special Google Ads conversion pixel in our site's code. The pixel uses cookies from Google LLC regarding the Google Ads service. From within our site, using the cookie management mechanism, you can disable these cookies. You can manage ad settings directly on Google's side: https://adssettings.google.com/.
• Details related to data processing within Google Ads are on the page: https://policies.google.com/privacy.

3.6. Facebook Ads and Insights.

• We use marketing and analytical tools available within the Facebook service (Meta Platforms Inc. based in the USA).
• The goal is to market our own products or services and for analysis and statistics.
• Within our site, we have implemented the Facebook Pixel, which automatically collects information about your use of our website in terms of viewed pages, for the purpose of directing personalized ads to you based on your behavior on our website.
• Information collected within the Facebook Pixel does not allow for your identification. Thanks to them, we only have the ability to see what actions you took within our site. We can also check what age range you are in, what gender you are, and where you connect to the Internet from.
• Details about Facebook's privacy policy can be found at: https://www.facebook.com/privacy/center.

3.7. Social tools.

• Plugins and other social tools provided by social networking sites, such as Facebook, Instagram, X (Twitter), YouTube, are used on our website.
• By viewing our website containing such a plugin, your browser establishes a direct connection with the servers of the social network administrators (service providers). The content of the plugin is transferred by the respective service provider directly to your browser and integrated with the site. Thanks to this integration, the service providers receive information that your browser viewed our site, even if you do not have a profile with the respective service provider or are not currently logged in. Such information (along with your IP address) is sent directly by your browser to the server of the respective service provider (some servers are located in the USA) and stored there. If you have logged in to one of the social networking sites, this service provider will be able to directly attribute the visit to our site to your profile on the respective social networking site.
• You can also completely prevent the loading of plugins on the site by using appropriate extensions for your browser, e.g., script blocking.
• Logging out of the respective social networking site before visiting our website will prevent the attribution of data collected during the visit to our website directly to your profile on the respective site.
• If you use a given plugin, e.g., by clicking the "Like" or "Share" button, the corresponding information will also be sent directly to the server of the respective service provider and stored there.
• The purpose and scope of data collection and its further processing and use by service providers, as well as the possibility of contact and your rights in this regard and the possibility of making settings ensuring the protection of your privacy are described in the privacy policy of individual service providers: Facebook - https://www.facebook.com/privacy/center,

Instagram - https://privacycenter.instagram.com/policy,

X (Twitter) - https://twitter.com/en/privacy,

YouTube - https://policies.google.com/privacy?hl=en.

3.8. Google Tag Manager.

• We use the Google Tag Manager tool provided by Google LLC.
• The Google Tag Manager tool is used to manage website tags through an interface. With the help of Google Tag Manager, we control our advertising campaigns and the way you use our pages.
• Google Tag Manager implements only tags. Its use does not involve saving cookies or collecting personal data. This tool enables other tags to operate, which in certain circumstances may collect data. However, Google Tag Manager does not access this data.
• If the saving option for the domain or cookies has been deactivated, this will apply to all tracking tags implemented via Google Tag Manager.
• We carry out activities in this area based on our legally justified interest in the form of marketing our own products or services and optimizing our websites.

3.9. Hotjar.

• We use the Hotjar tool provided by Hotjar Limited.
• Hotjar records every visitor to our site and allows for the playback of a video recording of their movement on our site, as well as the generation of so-called heatmaps.
• The Hotjar tool does not record the process of filling out forms, and therefore we do not have access to information that allows us to identify you.
• We carry out activities in this area based on our legally justified interest consisting of creating statistics and their analysis in order to optimize our websites.

3.10 Yandex Metrica.

• We use the Yandex Metrica analytical tool provided by Yandex LLC.
• Yandex records every visitor to our site, collects information related to their activity on the site, and allows for the playback of a video recording of their movement on our site, as well as the generation of so-called heatmaps.
• The Yandex tool does not record the process of filling out forms, and therefore we do not have access to information that allows us to identify you.
• We carry out activities in this area based on our legally justified interest consisting of creating statistics and their analysis in order to optimize our websites.
• Details related to data processing within Yandex can be found on the Yandex Metrica privacy policy page: https://yandex.com/legal/privacy/.
• You can block the Yandex tracking code at any time by following the steps described here: https://yandex.com/support/metrica/general/opt-out.html.

3.11. Smartsupp.

• We use the Smartsupp chat provided by Smartsupp.com.
• In this way, we provide you with the possibility of communicating with us via chat, based in this regard on our legally justified interest.
• The script handling the chat uses cookies to ensure the proper functioning of the chat.
• It is possible to disable cookies related to the chat from the level of cookie management on our site, but in this way you will lose the possibility of communicating with us via chat.
• The chat functionality involves the processing of personal data; in this case, the personal data processor is Smartsupp.

3.12. Disqus.

• We use the system provided by Disqus Inc. based in the USA, which gives you the possibility of leaving comments on our pages.
• The Disqus comment system uses cookies to ensure its proper functioning.
• Disqus may also use information collected through cookies for marketing purposes, which remains outside of our influence.
• Privacy details of the Disqus system can be found at: https://help.disqus.com/terms-and-policies/disqus-privacy-policy.
• It is possible to disable cookies related to the chat from the level of cookie management on our site, but in this way you will lose the possibility of communicating through comments.

3.13. Content from external services.

• Our pages embed content from external services, in particular videos from YouTube.
• Therefore, cookies from Google LLC related to the YouTube service are used, including DoubleClick cookies.
• Preventing the attribution of data collected during video playback or viewing other content on our website directly to your profile on the respective service is possible by logging out of that service before visiting our site, as well as, for example, by script blocking.
• Cookies related to YouTube are loaded only when a video is played, and therefore refraining from watching the video will prevent them from being loaded.
• The purpose and scope of data collection and its further processing and use by service providers, as well as your other rights related to this, are described in the privacy policy of the respective service providers.

3.14. TikTok pixel

• We use marketing tools available within the TikTok service, operated by TikTok Technology Limited, based in Ireland, for marketing our own products or services and for analysis and statistics.
• Within our site, we have implemented the TikTok Pixel, which we use to optimize campaigns and measure ad effectiveness. In addition, we can track site visitor actions, such as "view page" or "buy," and create audience segments to re-engage previous site users or model lookalikes to find new customers.
• The TikTok Pixel collects information available through standard web browsers, such as Chrome. These include: information about the ad that the TikTok user clicked or about an event that was triggered, the start time of the pixel event (used to determine when actions took place on the site, for example, when a page was viewed, when a product was purchased, etc.), the IP address used to determine the geographic location of the event and the device brand, model, operating system, and browser information.
• You have full control over whether TikTok displays personalized ads in the TikTok app. TikTok does not display personalized ads without the user's consent. You can enable personalized ads by clicking "Me" in the TikTok app, visiting the settings page, pressing the three dots in the upper right corner, then clicking "Personalization and data," and then using the toggle. You can change this setting at any time.
• More information about the privacy and cookies policy can be found on the dedicated TikTok page https://www.tiktok.com/legal/privacy-policy-eea?lang=en.

Remember that if any information provided by us regarding the privacy policy or cookies is unclear to you, we are available for you at the email address info@inkluz.com