Data Protection Policy (Annex 1 to the Terms & Conditions)
Services – means any product, service, content, functionality, technology or function, all related websites and applications that we offer you.
Portal – means websites, applications and mobile websites or other online content through which we offer our Services.
The Administrator of your data in the provision of our services is All Colors Agata Bielecka, ul. Potrzebna 3/19, 02-448 Warsaw (hereinafter referred to as “Wrapsbazaar.com“, “we”, “us” or “our”), entered into the Central Register and Information on Economic Activity under the number NIP 835 148 51 22, REGON 146643673.
Registration and other information about your account
During your registration to use our Services, we may collect the following information about you:
Providing the above data is necessary to use the services offered by Wrapsbazaar.com .
While using our Services, you may also voluntarily provide the following additional personal information:
If you use certain functionalities of the Portal, for verification purposes, we may request you to provide additional data such as a mobile phone number (for example when you publish a paid Offer for the first time or when we have introduced restrictions on the number of free Offers in our Portal). In these situations, the lack of additional data that we ask you for will prevent you from using these functionalities of the Portal.
In justified cases, when a violation of the Regulations is suspected, which is actng to disadvantage of other Portal Users, we may ask you to provide us with additional information related to the transaction (for example, a copy of the proof of sending the parcel). In such cases, the basis for processing this category of your personal data by us is our legitimate interest in acting against violations of the Regulations and providing Users with the possibility of using a safe and friendly Portal.
Communication via messages in our Portal
When you use the message function to communicate with other Users, we collect the content that you provide via this functionality.
Phone communication and correspondence
In the case you contact us by phone or email, we collect all information that you decide to provide during a conversation or during correspondence with our employees or representatives. Please note that phone conversations can be recorded. If you oppose the recording of phone conversations, the conversation will not be continued, and you can use other available forms of communication.
When you use our Portal, we automatically collect the following information about you:
Data about the device
Data about your activity on the Portal
We receive your personal data from various third parties (and public sources) such as listed below:
• Some technical and usage-related information obtained from analytical service providers such as Google.
• Address and contact data related to business operations obtained from information providers, such as business intelligence services and entities building bases of potential contractors and publicly available registers (for example Polish Central Registration and Information on Business Activity).
• Other users of the Portal, to the extent that they correspond with us regarding our Services or transactions that you have with them (for example shipping confirmation data, information about the discrepancy of Goods comparing to the Offer, information on potential frauds).
Our Services are not directed to children under 16 years old and we knowingly do not obtain any information about them. If you become aware that a person under 16 has provided us with their personal information, we will delete it immediately.
We will use your personal data only in accordance with the law. We usually process your personal information when:
• It is necessary to conclude or perform the contract (remember that by using our Services you conclude a contract for the provision of electronic services),
• It is necessary for our legitimate business interests, consisting in improving our Services and providing you with access to a secure and efficient Portal,
• It is necessary to fulfill the legal obligation imposed on us.
In certain circumstances, we may also process your personal information based on your consent. In such cases, when obtaining your consent, we will inform you about the purpose of the processing and the category of personal data being processed.
Below is a description of how we process your personal data and the legal basis on which we based our activities. In addition, when it is applicable, we have identified and described our legitimate interests.
If you log in using your e-mail ID, we will use your e-mail address to identify you as a User and provide you with access to our Portal.
If you log in using your Facebook account, we will use your name and email address from your Facebook profile to identify you as a User of our Portal and provide you with access to the Portal.
The above login information is also used by us to provide Services in accordance with our Regulations.
We use your email address and mobile phone number (via SMS) to send you suggestions and recommendations for our Services that may be of interest to you.
The above information is processed for the proper performance of the contract that you have concluded with us and on the basis of a legally justified interest of our marketing activities, consisting in offering you Services.
We use data about user activity (for example click sequences within the Portal) to:
• offer you personalized content, such as better search results when using our Services;
• determining how long and how you navigate our Portal in order to learn about your interests and improve our Services. For example, based on information about the content that you are interested in, we can give you suggestions of other interesting materials;
• monitoring and reporting the effectiveness of marketing campaigns to our business partners and for internal business analyzes.
We use your location data for the following purposes:
• combining anonymous and aggregate information about the characteristics and behavior of Wrapsbazaar.com Users, including for business analysis, segmentation and development of anonymous profiles;
• supporting the development of our Portal and personalizing the content that is directed to you. For example, with the help of a location and to provide you with greater convenience of shopping, we can display lists of Offers from your neighborhood;
• measuring and monitoring your interactions with advertising banners of third parties that we place on our Portal.
Based on login information that contains your email ID, we recognize various devices (such as a desktop computer, mobile phone, tablet) used by you to access the Portal. It allows us to combine your activity in our Portal on all devices, and also helps you provide the same convenience of using the Portal no matter what device you use.
We process the above information based on the premise of our legally legitimate interest, to improve your convenience of using the Portal and for the proper performance of the contract you have concluded with us.
In order to enable you to use the increasingly convenient Portal and new useful functionalities, we are constantly working on the development of our services. In order to develop new solutions, such as the system of effective recommendation of Offers, we can conduct various types of tests. In this case, we may process your personal data based on our legitimate interest in the development of our Portal. In order to protect your interests, we have implemented data protection mechanisms that can be used to develop new services, such as pseudonymisation or data encryption.
• We use your mobile phone number, login details and unique device identifiers to administer and protect our Portal (including diagnostics, data analysis, testing, fraud prevention, IT maintenance, support, reporting and data hosting).
• For the purposes of preventing abuse and promoting security by blocking spam or offensive messages that may be sent to you by other users, we analyze your communication through the messages function.
We process the above information for the proper performance of the contract you have concluded with us, to improve our Services and based on the premise of our legitimate interest in the prevention of abuse.
The applicable privacy laws grant you certain rights related to the processing of your personal data. The nature of our actions determines the scope of your rights.
The manner of implementing your rights
In order to ensure the implementation of your rights, we have provided appropriate functionalities within your account. By using the available functions, you can correct your personal data, receive a copy of it, or request to delete the account and related personal data. As we care about the safety of our Users’ personal data, requests regarding the implementation of your rights should be reported from the level of the Wrapsbazaar.com account functionality. Only this way that we have a chance to verify whether a specific request has been made by the data subject (i.e. our User). In addition, remember that deletion of your data is possible only after the completion of our services, i.e. after deleting the account of Wrapsbazaar.com. We also strive to ensure that the right functionalities are available in our other services.
If you want to implement any of the rights described below, please go to your account / privacy settings.
The right to access your personal data. This right allows you to receive information about whether we process personal data about you, and if so, the right to receive a copy of the personal data we process. The right to access your personal data allows you to verify that we process it in accordance with the law.
The right to rectify your personal data. This right provides the opportunity to request correction of incomplete, untrue or outdated data that we process. In some cases, when we process your request, we will need to verify the correctness of the new data you provide us with.
The right to limit the processing of your personal data. This right allows you to ask us to stop processing your personal data in the following situations:
(a) if you want us to check the accuracy of the data;
(b) if our processing is illegal;
(c) where you need information to establish, investigate or defend claims, even though we no longer need your data for our own processing purposes;
(d) when you object to our processing, but we must verify that we still have overriding and legitimate grounds for continuing the processing of your personal data.
The right to delete your personal data. This right allows you to request removal of your personal data if it is no longer necessary for the purposes for which it was collected. You can also request that we delete your personal data if you have successfully exercised your right to object to the processing (see below), if we process your data unlawfully or are required to remove your personal data in order to comply with the legal obligation set out in provisions of applicable law. Remember that in some cases, we are required to process your data based on applicable laws and we cannot process your request. For more information, see section 8.
The right to object to the processing of data concerning you in a situation where we process your data based on the premise of a legally legitimate interest (ours or third parties). You can bring the right of opposition for reasons related to your particular situation when, in your opinion, the processing affects your rights or freedoms. You also have the right to file an objection if we process your data for direct marketing purposes. In some cases, we can demonstrate that we have a legitimate basis for processing data that overrides your rights and freedoms (for example, the need to ensure the security of the Portal and the prevention of fraud). In such cases, the right to object is not connected with the removal of your personal data.
The right to transfer your personal data. In implementing this right, we will provide you or a third party identified by you with your personal information in a structured, commonly-used, machine-readable format. Remember that you are entitled to this right only in relation to data processed on the basis of consent or the condition for performance of the contract you have entered into with us, and the processing itself takes place in an automated manner (in information systems).
If you have given us permission to process your personal data, you have the right to withdraw it at any time. Withdrawal of consent does not affect the lawfulness of the processing that was made on the basis of consent before its withdrawal.
The exercise of rights is, in its principle, free of charge. You will not have to pay a fee for exercising the right of access to your personal data (or for the performance of any other rights). However, we may charge a reasonable fee if your request is manifestly unjustified or excessive, in particular because of its continuing nature. In these cases, we may also refuse to comply with your request.
Time to fulfill requests. We strive to respond to all legitimate requests within one month. If your request is particularly complex or you made several requests, it may take us longer than a month to recognize them. In this case, we will inform you of the extension of the deadline and provide you with current information regarding the implementation of your request.
You also have the right to file a complaint to the appropriate supervisory authority at any time, in accordance with the information indicated in section 11.
We will be grateful if, before filing a complaint to the supervisory body, you will give us the opportunity to address your case and concerns related to our action. For this reason, please contact us by email email@example.com.
We will communicate with you via email, SMS or by notifications from our Portal. The communication will be aimed at confirming your registration, informing you when your Offer becomes active and/or expires, and in the case of other transactional messages related to our Services. Due to the fact that sending such messages to you is necessary from our perspective, you may not be able to opt out of receiving them.
However, you can at any time opt out of the marketing communication you receive by clicking the appropriate link placed in the email or SMS sent to you, or by changing the notification settings as part of your account Wrapsbazaar.com. In case of problems or difficulties, please contact us via email: firstname.lastname@example.org.
You can receive marketing communication when:
• you asked us to receive such information by agreeing to marketing communication;
• you provided us with your details by taking part in the competition; or
• you reported your participation in the promotional campaign.
For the purposes of section 4, we may share your personal data with the following categories of recipients:
Third parties providing services: We use third party services that help us provide specific solutions related to our Services, e.g. data storage in the Amazon Web Services cloud and Microsoft Azure. Providers of such services may be established both within the European Economic Area and outside it.
We conduct inspections of our suppliers and require them to ensure the security of your personal data and to process it in accordance with the law. We do not allow our suppliers to process your personal data for their own purposes. As part of our cooperation, we reserve that suppliers may process them only for clearly identified purposes, in accordance with our instructions.
Marketing and analytics service providers: In order to improve our Services, we sometimes provide information about you (in a form that prevents the identification) to analytical services providers, who help us analyze how users use our Services / Portal. For the purposes of monitoring and reporting the effectiveness of our business partners’ campaigns and for internal business analyzes, we share information with them in a way that prevents users from being identified. For more information on our analytical service providers, please see our Policy on Cookies and Similar Technologies.
Law enforcement, supervisory bodies and others: We may disclose your personal data to law enforcement authorities, supervisory bodies, public authorities, entities performing public tasks or acting on behalf of public authorities and other third parties. The disclosure of such data takes place in connection with the performance of legal obligations.
Information available to the public: If you use our Services and decide to put a specific item for sale, you may decide to disclose certain personal data to other users of the Wrapsbazaar.com Portal. This information may include your name, email address, your location and contact number. Remember that any information that you disclose to other users may be forwarded, so you should take special care in this matter.
Other Users: When you use our Services that enable communication with other Users, we share your data to the extent related to such Service. In addition, if you use messaging functionality on the Portal, we share your data related to correspondence and the User name preceding the domain of the email address used to set up a Wrapsbazaar.com Account (example @ gmail.com).
In situations where we transfer your personal information outside of the “EEA”, we guarantee that a similar level of protection is ensured by introducing at least one of the following safeguards:
• We will only forward your personal data to countries that the European Commission has identified as providing an adequate level of protection for your personal data. Detailed information is available here: European Commission: Adequacy of non-EU countries
• By using the services of certain suppliers, we can use agreements approved by the European Commission that provide personal data with the same protection as those enjoyed in the European Union. Detailed information is available here: European Commission: An agreement model for the transfer of personal data to third countries
• If our service providers are based in the United States of America, we may provide them with data if they have been included in the Privacy Shield, which requires them to provide similar protection for data transferred between Europe and the United States. Detailed information is available here: European Commission: EU-US Privacy Shield
You can get a copy of the appropriate security by contacting us using email: email@example.com.
The data we collect about you will be stored and processed both within the European Economic Area and outside of it, on properly secured servers, in order to provide our users with the highest quality of services, for example fast websites or continuously developed mobile applications.
We store your data for as long as it is necessary to achieve the purposes for which it was collected, including as part of fulfilling legal obligations, tax and accounting or for reporting purposes.
In order to determine the appropriate retention period for personal data, we take into account the amount and nature of the data being processed, including the nature of the particular category data. We also take into account the potential risk of unauthorized use or unauthorized disclosure of your personal data, the possibility of meeting the purposes of processing by other means and the content of provisions relating to the personal data being processed.
We store your personal data related to the Wrapsbazaar.com account for the duration of its possession on the Portal for the purpose of providing services provided in accordance with the Regulations, as well as for marketing purposes.
After closing your account, we may store your personal data to the extent and for a period of time that is necessary to fulfill legal obligations or our legitimate interests (for example to combat fraud).
Personal data related to cookie technology is stored for a period of time corresponding to the lifecycle of cookies or until they are deleted by the User.
If you have any questions regarding the retention periods of your data, please contact us by email: firstname.lastname@example.org.
All information we receive about you is stored on properly secured servers. We have also implemented appropriate and necessary technical and organizational measures to protect your data. Wrapsbazaar.com constantly assesses the level of security within its network and monitors internal regulations and procedures designed to
(a) protect data against accidental or unlawful loss, access or disclosure
(b) identify foreseeable risks to network security Wrapsbazaar.com
(c) minimize security threats, including through risk assessment and regular testing.
In addition, we ensure that all payment-related data is encrypted using SSL technology.
Remember that, despite the measures we have implemented to protect your personal data, sharing information via the Internet or publicly available networks is never completely secure and there is a risk that access to your personal data will be obtained by unauthorized third parties.
In order to obtain additional information or exercise your rights, check your account settings in “My Bazaar” tab or contact us by email: email@example.com or via the Contact tab in our Portal. If you want to contact us in matters related to the processing of your personal data, you can also send a letter to our address:
All Colors Agata Bielecka,
ul. Potrzebna 3/19
with an annotation on the envelope: “Wraps Bazaar”.
In matters related to the protection of personal data, you can contact
President of the Personal Data Protection Office
ul. Stawki 2