Privacy Policy

User: Person using the service Service: Website or an internet system used by the user The Data Controller and website operator is:

Ecowipes EWS Spółka z ograniczoną odpowiedzialnością Spółka Jawna with its registered office at ul. Nowogrodzka 47A, 00-695 Warsaw, entered into the register of entrepreneurs maintained by the District Court for the Capital City of Warsaw in Warsaw, 12th Economic Division of the National Court Register, under the number KRS 0000492515, NIP (Tax Identification No.): 966-197-86-64.

1. Personal data collection and usage

1.1. who is processing personal data collected via www.ecowipes.pl
The Data Controller is EcoWipes EWS Spółka z ograniczoną odpowiedzialnością Spółka Jawna with its registered office at ul. Nowogrodzka 47A, 00-695 Warsaw, entered into the register of entrepreneurs maintained by the District Court for the Capital City of Warsaw in Warsaw, 12th Economic Division of the National Court Register, under the number KRS 0000492515, NIP (Tax Identification No.): 966-197-86-64.

At the request of EcoWipes, the data processor for specific purposes (sending newsletters, marketing activities) shall be CUKIER works Spółka Akcyjna with its registered office at ul. Bzowa 13A, 02-708 Warsaw, entered into the Register of Entrepreneurs of the National Court Register maintained by the District Court for the Capital City of Warsaw in Warsaw, 13th Economic Division of the National Court Register, under the number KRS 0000719720, NIP (Tax Identification No.): 5213817176.

1.2. what is the purpose of data processing?
When you use www.ecowipes.pl, your personal data are collected and processed for purposes related to the functionalities of the website. Personal data are processed on the basis of the consent given by the User and in cases where the applicable provisions of the law authorize the Data Controller to process personal data on the basis of the law, or for the purpose of executing the agreement made by and between the parties. The website collects information on the users and their digital behavior through the following functionalities:

• newsletter subscription,
• signing up for dedicated programs, competitions or events,
• request for proposal or cooperation inquiry (including creating content for the website),
• request for marketing information,
• request for contact,
• use of online applications or tools,
• cookies.

We will be processing your personal data in the manner described in this Privacy Policy. Your personal data will not be used for any other purposes, unless you give your consent, or it is required or permitted by the applicable provisions of the law or professional standards.

1.3. What is the basis for the processing of my personal data by ecowipes?

Depending on the purpose of processing your personal data, EcoWipes has the necessary legal basis for processing, for instance:

• when the processing of your data is necessary for the performance of the contract to which you are the party, or in order to take steps at your request prior to entering into the contract – Article 6 sec. 1 letter b of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, GDPR),
• when you are asked for consent to the processing of your personal data for one or more specific purposes – Article 6 sec. 1 letter a of GDPR,
• when the processing of your data is necessary for the purposes of the legitimate interests pursued by us, such as accepting and answering your inquiries – Article 6 sec. 1 letter f of GDPR,
• when the processing of your data is necessary for compliance with a legal obligation to which we are subject, e.g. when we are required to disclose your personal data to the relevant government authorities – Article 6 sec. 1 letter c of GDPR.

Other examples of the aforementioned legitimate interests include:

• preventing abusive or criminal acts, and protecting our IT systems,
• personalizing the users’ online experience and improving the website usefulness and performance,
• conducting and analyzing our marketing activities, unless the relevant provisions of the law require a separate consent.

1.4. Are “sensitive” personal data also being processed?

EcoWipes is not purposefully collecting any “sensitive” personal data. Sensitive data include personal data on the user’s racial or ethnic origin, political views, membership in trade unions, religious views/denomination or life philosophy, health, sexuality, sexual orientation or criminal records, as well as genetic or biometric data.

2. Automatic data collection

In some cases, EcoWipes and its service providers use cookies, web beacons and other technologies to automatically collect specific information during the user’s visits to our website, or via e-mail addresses. Those data are collected in order to better understand and improve the website performance and functionality, and to assess the efficiency of marketing activities.

The information collected in this manner is not always personal data, i.e. data which make it possible to identify an individual user, but personal data may be collected as well, e.g. when the IP address or geolocation data can be connected to the user’s e-mail address.

2.1. Cookies

Cookies are placed by our website on the user’s computer or another device with Internet connection at each visit to enable the website to remember the user’s computer or device.

The website will display a banner asking for consent to the use of cookies on the users computer. If the user refuses to consent, the operations conducted with the use of the user’s computer or device with Internet connection will not be tracked for marketing purposes. Another type of cookies, known as session cookies, may be required for a specific website function to work. These cookies are not blocked if the user does not consent to the use of cookies on their computer. The user’s choice will be stored in the cookie file for 90 days. If the user wishes to change it, they should delete cookies from their web browser.

Even though most web browsers automatically allow cookies on the user’s computer, the user may refuse cookies by changing the relevant browser settings (usually found in the Tools or Preferences menu of the browser). The user may also delete cookies from their device at any time. However, it should be noted that by refusing cookies, the user will not be able to use all functionalities of the website.

Cookies do not contain the user’s e-mail address or their personal data. Website reports may include other identifiers, such as IP addresses, which are used to determine the number of unique users of the website.

2.2. Google analytics

Our website www.ecowipes.pl uses Google Analytics. In order to give the users visiting our website a broader choice of options of how their data collected by Google Analytics are used, Google has developed a browser add-on blocking Google Analytics. The add-on interfaces with the Google Analytics JavaScript protocol (ga.js) to communicate that the data on the website visits should not be transferred to Google Analytics. The Google Analytics Opt-out add-on does not block the transfer of data to the website itself or other online analytic services.

2.3. Web beacons

Web beacons are small image files embedded in the website which make it possible to collect specific information transmitted by the user’s computer, such as IP address, the website visit time, or cookies installed by the same server on the previous visits. Web beacons are used in accordance with the applicable provisions of the law.

The user may block web beacons by refusing specific cookies related to the given beacon. The beacon is still able to record anonymous visits from the specific user’s IP address, but the information stored by cookies are not recorded.

2.4. Geolocation tools

Our website www.ecowipes.pl may collect and use the geolocation data of the user’s computer or mobile device. The geolocation data are collected in order to provide information to the users on the available services in the area which may be interesting or useful to them.

3. Widgets and social media apps

Our website www.ecowipes.pl may include functions for sharing content in third-party social media apps, such as Facebook or LinkedIn. All social media apps can collect and use data on the users’ activity on www.ecowipes.pl (see the information above on cookies used for sharing content in social media). All personal data provided by the users via the social media apps may be collected and used by other users of those social media apps, and the interactions in the apps are subject to the provisions of the privacy policies of the social media app providers.

Furthermore, our website www.ecowipes.pl may also include blogs or discussion boards (referred to jointly as “social functions”). The purpose of the social functions is to make sharing knowledge and content easier. All personal data provided by the users using any social functions may be shared with other users of the given social function (unless it is specified otherwise during the collection of the data), over which we have limited or no control.

4. Links to other websites

Please remember that the hyperlinks placed on www.ecowipes.pl may redirect the user to other websites. Those websites may have different privacy policies and the provisions of those policies may differ from ours. We encourage the users to read the privacy policy of every visited website before providing their personal data.

5. Disclosure of and entrusting the processing of personal data

EcoWipes does not disclose any personal data to unaffiliated entities, unless it is necessary due to our operations, a submitted report, or when the applicable provisions of the law require or permit such disclosure. With respect to our business operations, we may transfer personal data e.g. to public administration authorities or other third parties. If it is necessary and required under the applicable provisions of the law, EcoWipes shall disclose the personal data in response to the inquiries of judicial or law enforcement authorities, and also for the purpose of conformity with the relevant provisions of the law or official orders.

Furthermore, EcoWipes may entrust the processing of personal data to other third parties working with EcoWipes or acting on our behalf, for the purposes set forth in this Privacy Policy, including for the purpose of providing support services in the IT infrastructure, and for marketing activities.

The requirement to disclose personal data may also arise from data privacy or security audits, and/or during the consideration of complaints or taking actions related to security risks. EcoWipes does not sell to third parties any personal data which those third parties might then use for their own marketing purposes.

6. Access to data and powers

If the user provides their personal data, they usually have the access necessary to alter their data or rectify any errors. The user may also request ecowipes@ecowipes.com.pl to update or erase specific data; in such cases, the data controller shall take every appropriate effort to fulfil such request, provided that it conforms to the applicable provisions of the law.

With respect to the processing of personal data, the user has the following rights specified in the GDPR:

• the right to access their personal data (including obtaining confirmation that the data are being processed and the information on the purposes, sources and categories of processed data, or the period of retention thereof), which also includes the right to a free-of-charge copy of their personal data (for any further copies requested by the data subject we may charge a reasonable fee based on administrative costs),
• the right to rectify personal data (if the data are inaccurate), which also includes the right to complete the incomplete personal data – in this case, we may ask you to provide an additional statement,
• the right to erase personal data (the so-called “right to be forgotten”), e.g. when the data are not necessary for the purposes, for which they were collected, the consent to processing has been withdrawn, or there is no other legal basis for processing,
• the right to restrict processing of data, e.g. when you are questioning the accuracy of your data – for the period necessary for us to verify the accuracy of the data in question,
• the right to object to processing,
• the right to data portability, including the right to obtain from us the personal data you have provided, in a structured, commonly used and machine-readable format,
• the right to withdraw consent to the processing of your data (whereby the withdrawal of consent shall not affect the legality of the processing conducted on the basis of the consent before it was withdrawn),
• the right to lodge a complaint to the President of the Personal Data Protection Office when you believe that the processing of your personal data violated the provisions of GDPR.

7. Amendments to the privacy policy

EcoWipes may make amendments to this document to reflect the current provisions of our Privacy Policy. In the event of an amendment, the date of the last update on the first page of this document shall be changed accordingly. We encourage our users to review our Privacy Policy on a regular basis.