Terms used in this document have the following meaning mean:
Privacy Policy – this Privacy Policy
Personal data –means any and all information related to an identified or identifiable natural person („data subject"); an identifiable natural person is a person who can be identified directly or indirectly, in particular with regard to an identifier such as name, identification number, location data, internet identifier, or one or more factors specific to such natural person's physical, physiological, genetic, mental, economic, cultural, or social identity.
Data subject – any natural person whose personal data is processed by the Data Controller.
Data protection provisions – means any and all generally applicable provisions of the European Union, as well as locally relevant provisions of its Member States, including, among others, acts, directives, and regulations related to protection of personal data, in particular the GDPR (as defined below).
GDPR– Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals 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);
Data Controller – Veneo Sp. z o.o. with its registered office in Krakow, at the address: Al. Juliusza Słowackiego 5, 31-159 Krakow.
Veneo – Veneo Sp. z o.o. with its registered office in Krakow, at the address: Al. Juliusza Słowackiego 5, 31-159 Krakow.
II. Personal data processing
In connection with the conducted business activity, the Data Controller collects data for specified, lawful purposes, processes such in accordance with the law and does not subject such to further processing incompatible with these purposes. Data is collected only in an adequate and necessary scope in relation to the purposes for which it is processed.
The Data Controller makes every effort in order to protect data against unauthorized access by third parties and in this respect applies organizational and technical security measures at a high level. The Data Controller does not provide data to any unauthorized recipients, in accordance with the mandatory provisions of law in this regard.
Data Controllers/Entities entrusted with the processing of your personal data
In order to ensure integrity and confidentiality of data, the Data Controller has implemented procedures allowing access to personal data solely to authorized persons and solely to the extent necessary in connection with the tasks performed thereby.
The Data Controller also takes all necessary steps in order to ensure that its subcontractors and other cooperating entities guarantee application of appropriate security measures in each case when they process personal data at the request of the Data Controller.
The Data Controller carries out ongoing risk analysis and monitors adequacy of the data security applied to identified threats. If necessary, the Data Controller implements additional measures to increase data security.
IV. What are the purposes of processing your personal data?
Purposes related to offering or sale of Veneo products and services via the veneo.pl website and provision of related services Your personal data is processed in order to provide you with information about the Veneo commercial offer, conclude with you and implement purchase/sale contracts for products and Veneo services via the veneo.pl website, and to handle other matters related to commercial offers or contracts for the purchase/sale of Veneo products and services.
Marketing and analytical goals With your consent, personal data may be processed for marketing purposes, including sending you commercial or marketing information related to Veneo products and services or (newsletter), for profiling and analytical purposes, as well as detecting bots and abuses, and statistical measurements. In addition, your data may also be processed in order to match the content displayed on websites, including commercial or marketing messages, to your interests. After obtaining your consent, the data may be processed by the Data Controller and Trusted Partners.
Online social media If you are a member of communities operating around the Veneo brand/company social profiles run as part of popular online social networks, your data is processed in order to enable the conduct and ongoing management of such profiles, including, among others, to communicate with members of such communities, organize promotional campaigns or events - on the terms specified in the functionalities and regulations of individual social platforms. In addition, data may be processed for the purpose of pursuing claims and defending against claims, as well as for statistical and analytical purposes.
Traditional or e-mail correspondence If you send to Veneo, by means of traditional mail or e-mail, correspondence not related to the sale of Veneo products and services or services provided to you or another contract concluded with you, the personal data contained in such correspondence is processed only for the purpose of communication and settling the matter to which this correspondence applies. Only personal data relevant to the matter related to the correspondence is processed.
Telephone contact If you contact Veneo by phone, in matters not related to the contract concluded with you or services provided to you, we require personal data only if this is necessary for handling the case to which the given contact relates.
Recruitment purposes If you are recruiting for a job or cooperation with Veneo, provide your personal data in the correspondence and recruitment documents sent to Veneo within the scope specified in the provisions of labour law. If you provide additional data, the Data Controller will assume that you consent to the processing of your data for recruitment purposes. Personal data contained in the correspondence and recruitment documents sent to Veneo (CV/resume, cover letter, or other documents) is processed for the purpose of:
execution of obligations under the law related to the employment process, including the Labour Code
carrying out the recruitment process in the field of data not required by law, as well as for the purposes of future recruitment processes
establishing or pursuing possible claims or defending against such claims.
Processing of personal data in IT applications If your personal data is processed in the ICT environment, it means that it may also be temporarily stored and processed in order to ensure security and proper functioning of IT systems - e.g. in connection with modifications, changes, and functional development of the application, detection of errors and irregularities in applications, backing up the application, as well as providing security and protection against abuse or attacks.
Zbieranie i przetwarzanie danych w relacjach biznesowych Data collection and processing in business relations In connection with the conducted activity, the Data Controller collects personal data also in other cases - e.g. during business meetings, at industry meetings, or by exchanging business cards - for purposes related to establishing and maintaining business contacts. In connection with cooperation of the Data Controller with business partners, including business clients and suppliers, the Data Controller processes contact details of persons indicated as business contacts in relation to the Data Controller, e.g. persons responsible on the part of the partner for performance of the contract with the Data Controller. The Data Controller processes contact details of such persons for purposes of ongoing communication with business partners and maintaining contacts with them.
Purposes related to conducting promotional activities or organizing marketing campaigns for Veneo clients and their brands with the use of dedicated websites (Landing Pages) or internet applications and provision of related services. Your personal data is processed for the purposes of providing you with information about promotional activities or marketing campaigns organized for Veneo clients and their brands (e.g. promotional campaigns, special campaigns, consumer contests, promotional lotteries, or other forms of promotion), enabling you to participate in promotions or organized marketing campaigns using dedicated websites (Landing Pages), web applications, or other communication methods as well as conducting promotions, issuing prizes, handling complaints and handling other matters related to promotional activities or organized marketing campaigns for Veneo clients and their brands.
V. What are the legal grounds for processing your personal data?
Purposes related to the offering or sale of Veneo products and services via the veneo.pl website and provision of related services. The legal basis for the processing of your personal data is:
your voluntary consent to the processing of data (Article 6(1)(a) of the GDPR) in order to provide you with information about the commercial offer
Performance of a contract to which the data subject is a party (Article 6(1)(b) of the GDPR).
Marketing and analytical goals The legal basis for the processing of your data for marketing purposes is your voluntary consent to the processing of data (Article 6(1)(a) of the GDPR). In order to adjust the content displayed on websites, including commercial or marketing messages, to your interests, profiling and analytical purposes, as well as detecting bots and abuses and statistical measurements (Google Analytics), the legal basis for the processing of your personal data is the legitimate interest of the Data Controller (Article 6(1)(f) of the GDPR).
Online social media The legal basis for the processing of your personal data is the legitimate interest of the Data Controller (Article 6(1)(f) of the GDPR).
Standard or e-mail correspondence The legal basis for the processing of your personal data is the legitimate interest of the Data Controller (Article 6(1)(f) of the GDPR), consisting in conducting correspondence activities addressed to them in connection with the conducted business activity.
Telephone contact The legal basis for the processing of your personal data is the legitimate interest of the Data Controller (Article 6(1)(f) of the GDPR), consisting in the need to settle a submitted matter related to the conducted business activity.
Recruitment procedures The legal basis for the processing of your personal data is:
the legal obligation incumbent on the Data Controller (Article 6(1)(c) of the GDPR in connection with the provisions of the Labour Code) consisting in performance of obligations arising from legal provisions related to the employment process, including the Labour Code,
your voluntary consent to the processing of data (Article 6(1)(a) of the GDPR) with regard to the data not required by law in the recruitment process, as well as for the purposes of future recruitment processes,
the legitimate interest (Article 6(1)(f) of the GDPR) consisting in establishing or pursuing any claims or defending against such claims.
Personal data processing in IT applications The legal basis for the processing of your personal data is the legitimate interest of the Data Controller (Article 6(1)(f) of the GDPR).
Data collection and processing in business relations The legal basis for the processing of your personal data is the legitimate interest of the Data Controller (Article 6(1)(f) of the GDPR), consisting in creating a network of contacts in connection with the conducted business activity or consisting in communication with business partners.
Purposes related to conducting promotional activities or organizing marketing campaigns for Veneo clients and their brands using dedicated websites (Landing Pages) or web applications and provision of related services The legal basis for the processing of your personal data is:
your voluntary consent to the processing of data (Article 6(1)(a) of the GDPR) for the purpose of providing you with information about conducted promotional activities or organized marketing campaigns and enabling you to participate in promotions or organized marketing campaigns
performance of a contract to which the data subject is a party (Article 6(1)(b) of the GDPR).
Data processing in connection with provision of services or performance of other contracts Rules for the processing of your personal data in connection with offered services related to conducting promotional activities or organizing marketing campaigns for Veneo clients and their brands and provision of related services, are set out in separate policies available on the websites of these services - e.g. PayU, courier companies.
VI. The requirement to provide personal data
Providing personal data in order to provide you with information about the commercial offer of Veneo, concluding and implementing contracts for the purchase/sale of Veneo products and services using the veneo.pl website and handling other matters related to commercial offers or contracts for the purchase/sale of products and services Veneo is necessary for the above-mentioned provision of information about the commercial offer as well as the conclusion and performance of contracts and the provision of services. If personal data is not provided, commercial offers cannot be presented, contracts cannot be concluded, and services cannot be provided.
Providing personal data for marketing purposes, including profiling and for analytical purposes, is voluntary. If you do not consent to the processing of personal data left by you as part of using the Veneo.pl website or other websites operated by Veneo, including those stored in cookies - your personal data will not be processed for this purpose.
Data processing in order to adjust the content displayed on websites, including commercial or marketing messages, to your interests, detect bots and abuse in Veneo services, or statistical measurements, it is necessary to ensure high quality Veneo services. Failure to collect your personal data for such purposes may prevent proper provision of services.
Providing personal data to enable you to participate in promotions or marketing campaigns organized for Veneo clients and their brands using dedicated websites (Landing Pages) or web applications (e.g. promotional campaigns, special campaigns, consumer contests, promotional lotteries, and other forms of promotion) is necessary to allow to participate in the above-mentioned promotions or organized marketing campaigns, issue prizes, handle complaints and handle other matters related to promotional activities or organized marketing campaigns. Where you do not provide your personal data, you will unable to take part in promotions or organized marketing campaigns.
VII. For how long will your personal data be processed?
The period of processing your data depends on the purpose of data processing and type and scope of provided services. The specified period of data processing may result from regulations, if such constitute the basis for processing. In the case of data processing on the basis of the legitimate interest of the Data Controller - e.g. for statistical and settlement purposes, for the purpose of pursuing claims or for security reasons - the data is processed for a period enabling its implementation or submitting an effective objection to the data processing. If the processing is based on your consent, the data is processed until withdrawal of such consent.
If the basis for the processing of your data is the necessity to conclude and perform a contract, including purchase/sale of Veneo products or services, or resulting from your participation in a promotion or marketing campaign organized for a Veneo client, your personal data will be processed until termination of such contract.
Your personal data will be processed for marketing purposes until withdrawal of your consent to such processing.
In terms of adjusting the content displayed on the websites of Veneo.pl and other websistes operated by Veneo, including commercial or marketing messages, to your interests, as well as detecting bots and abuses as well as analytical purposes and statistical measurements, your data will be processed for such purposes until you object or terminate your use of the Veneo offer and services.
The period of personal data processing may be extended if such processing is necessary to establish, investigate, or defend against possible claims, and after this period, only if and to the extent required by law. Following expiry of the processing period, the data is irreversibly deleted or anonymized.
Trusted Partners process data for the period necessary to achieve the purpose of processing, as specified in the relevant privacy policy of such Trusted Partner.
VIII. To what recipients will your personal data be transferred?
In connection with business operations requiring the processing of personal data, your data may be transferred to external entities processing personal data at the request of the Data Controller, including: providers of IT services and solutions, entities providing legal, accounting, or auditing services, entities providing consulting services, entities intermediating in electronic payments, entities providing postal or courier services, marketing agencies, recruitment agencies, research companies, whereby such entities process data solely in accordance with the instructions of the Data Controller.
Your data may also be transferred to entities authorized to obtain it on the basis of applicable law.
IX. Transferring data outside the European Economic Area
The Data Controller transfers personal data outside the European Economic Area (EEA) only when it is necessary and ensuring an adequate level of protection, primarily through:
cooperation with entities processing personal data in countries for which there has been issued a relevant decision of the European Commission;
use of standard contractual clauses issued by the European Commission;
application of binding corporate rules approved by the competent supervisory authority;
in the case of transferring data to the USA - cooperation with entities participating in the Privacy Shield programme, approved by the decision of the European Commission.
X. What are your rights related to the processing of personal data?
In connection with the processing of your personal data, you have the following rights:
the right to access your personal data, including obtaining a copy of the data. You can obtain information on how and to what extent we process your data and, additionally, a copy of your personal data. If your request includes copies of the data, you undertake to assist us by indicating a copy of the data you would like to receive. The Data Controller may charge a fee for the second and subsequent copies, of which you will be notified. The amount of the fee will correspond to the cost of its preparation;
the right to request rectification of personal data You can request rectification of your personal data (if it has been incorrectly saved or if it has changed);
the right to delete personal data (in certain situations) You can request deletion of your personal data (if there is no basis for the Data Controller to process it);
he right to limit data processing You can request restriction of the processing of your personal data (if you wish the Data Controller to process your personal data only to a limited extent, pending your objection or request for rectification of personal data, and also if you wish for the data to be stored in connection with your claims);
the right to object to the processing of your data If processing of your data is taking place on the basis of the legitimate interest of the Data Controller, you can object to such processing;
the right to lodge a complaint with the supervisory body dealing with personal data protection You have the right to lodge a complaint with a supervisory authority, i.e. the President of the Personal Data Protection Office. More information is available on the website of the office; To the extent that your data is processed on the basis of consent or as part of the services provided (data is necessary for the conclusion and performance of contracts and provision of services), you can additionally exercise the following rights:
the right to withdraw consent to the extent that your data is processed on the basis of such consent Withdrawal of consent does not affect the lawfulness of the processing which was conducted on the basis of consent prior to its withdrawal;
the right to transfer personal data, i.e. to receive your personal data from the Data Controller, in a structured, commonly used, machine-readable format, you can request that your data be transferred in a structured, commonly used, machine-readable format; In order to exercise the above rights, the Data Controller provides the following communication channels:
In order to exercise the above rights, the Data Controller provides the following communication channels:
by standard letter – address: Veneo Sp. z o.o., Al. Juliusza Słowackiego 5, 31-159 Krakow
An application with regard to the exercise of the rights of data subjects should, if possible, specify in an accurate manner what the request concerns, i.e. in particular:
what right the person submitting the application wishes to exercise (e.g. the right to receive a copy of the data, the right to delete the data, etc.);
what data the processing process a request concerns (e.g. activity on the Veneo website, receiving a newsletter with marketing information, etc.);
what purposes of data processing the request relates to (e.g. marketing purposes, analytical purposes, etc.);
If the Data Controller is unable to determine the content of the request or identify the person submitting an application on the basis of the submitted application, they will request such additional information from the applicant. A response to the application will be given within 30 days of its receipt. If extention of this period is necessary, the Data Controller will inform the applicant about the reasons for such extension. In the case of an application submitted by e-mail, the response will be given to the e-mail address from which the application was sent. In the case of an application submitted in writing (standard letter), the response will be given in writing (standard letter) to the address indicated by the applicant, unless the content of the letter indicates a desire to receive response to the e-mail address and if the e-mail address is given in the application.
XI. Contact with Data Controller
In matters related to the protection of personal data and the exercise of rights related to the processing of such data, you may contact us through the following communication channels:
by standard letter – address: Veneo Sp. z o.o., Al. Słowackiego 5, 31-159 Kraków
Veneo informs that cookies (text files) and other technologies are used on the pages of the Veneo.pl website and on other websites operated by Veneo, in order to record information about websites or subpages visited by the user and their activity
Cookie files (so-called "cookies") are tiny portions of information saved by a web browser. A cookie has no effect on the software or hardware. Cookies are associated only with the browser of a specific end device, without providing the user's name or surname (anonymous user). This is information saved by the server on the website user's end device, which the server can read on each occasion that it connects to the user's device.
The term "other technologies" refers to, among others, web beacons, pixels, and anonymous ad network tags.
Because ads and web beacons must be on to your web browser directly from ad network servers, these networks may display, edit, or set their own cookies as if you were requesting to access a website from their website.
For the purposes necessary to conclude or perform a contract with the user and to provide a better tailored offer, as well as with the express consent of the data subject, Veneo may use profiling, which means a form of processing consisting in the use of personal data for analysis or predictions about the user’s personal preferences and interests
XIII. Types of cookies
The following types of cookies are used on Veneo websites:
Authentication necessary cookies - information enabling the use of services available on the website, eg.authentication cookies used for services requiring authentication on the website;
Security cookies used to ensure security - information used in order to ensure security supporting mechanisms which prevent abuse on websites, including data leakage or detection of fraud in the area of authentication on the website;
Preferences functional cookies - information allowing to remember the settings selected by the user and user personalisation, eg. in terms of the language or region from which the user comes, font size, website appearance, etc.;
Performance performance cookies - information enabling collecting information on the use of website pages;
Advertising and Trusted Partners advertising cookies - information enabling users to provide advertising content more tailored to their interests. Veneo allows other entities to use cookies - the so-called "third party cookies" - information provided to Trusted Partners (service providers, in particular search, advertising, Internet research, etc.).
Veneo websites use two basic types of cookies:
session cookiessession cookies are temporary files stored in the end device of the website user until logging out, or until leaving the website, or turning off the software (web browser).
persistent cookies – persistent cookies are stored in the end device of the website user for the time specified in the cookie file parameters or until they are deleted by the user.
XIV. urposes of using cookies
Cookies are used for the purposes of:
Maintaining a session of the website user (after logging in), thanks to which the user does not have to re-enter the login and password on each subpage of the website;
Adjusting the content of websites to the user's preferences and optimizing the use of websites; in particular, these files allow to recognize the website user's device and properly display the website, tailored to their individual needs;
Matching the content of advertisements displayed on the Google advertising network (remarketing);
Remembering the lack of consent to display some content in the future;
Statistical and analytical purposes, including measuring user behaviour and traffic on the website pages using the Google Analytics mechanism;
Matching the content of advertisements displayed on Veneo websites;
Measuring effectiveness (conversion tracking) of actions carried out in the Google display network, partner programmes, and affiliate networks;
Using the mechanism of polls or surveys examining user preferences;
XV. Social Plugins
Information supporting functions, providing important information and content in accordance with the individual needs of the user, coming from the servers of entities running websites:
Facebook, which places the "Like" and "Recommend/Share" buttons on pages related to Facebook. For this purpose, a code referring to Facebook is placed on the relevant pages. By using the "Like" button or recommending an image or sections of the website, as well as by posting a comment, the user logs in to Facebook, where the Facebook privacy protection rules apply, available at: http://pl-pl.facebook.com/help/cookies
YouTube, which places video clips from YouTube on its website. For this purpose, a code referring to YouTube is placed on the pages. YouTube tracks video playback in accordance with the privacy policy available at: http://www.google.com/intl/en/policies/privacy/
Instagram, which places buttons for adding photos and videos on the pages of its website and the "Like" button, related to the Instagram website. For this purpose, a code referring to Instagram is placed on the relevant pages. By using the "Like" button and by posting a comment, the user logs in to the Instagram website, which is governed by the Instagram privacy rules, available at: https://www.facebook.com/help/instagram/155833707900388
XVI. Advertisement
Information necessary to show you a targeted advertisement or to obtain information about visits to advertisers’ websites. Similarly, our Trusted Partners may use cookies to determine the effectiveness of advertising. Cookies and other technologies allow you to serve advertisements to users more effectively, as well as collect collected audits, research and reports for advertisers
Veneo informs that it is a party to the contract with:
GOOGLE Inc. As part of advertising services, the software of Trusted Partners creates cookie files on the user's device, which, along with information collected on other websites, may be used to personalize content and ads. The privacy policies of the above-mentioned Trusted Partners can be found at the following addresses: https://policies.google.com/privacy?hl=pl
XVII. Profiling (including analytics)
Information on the use of websites which allows you to adapt advertisements to the preferences and habits of users. On the basis of this information, for example, general user profiles (e.g. age, gender, interests) can be created.
Decisions on matching the offer or granting a discount or other benefit may be made automatically on the basis of criteria such as gender, addresses of websites where purchases were made, number and frequency of purchases made. After determining the fulfillment of the criteria, the IT system automatically sends information about the granted benefit, e.g. a rebate.
XVIII. Cookies related to Internet network research/user behaviour research
Cookies related to Internet network research/user behaviour research come from the following Trusted Partners:
GOOGLE Inc.
Veneo informs that it is a party to the contract with:
GOOGLE Inc.
As part of analytical services, the Trusted Partners software activates an analytical code on the user's device that allows collection of data and observation of user behaviour, and creates cookie files on the user's device, which, in combination with information collected on other websites, can be used to personalize content, commercial and marketing messages, and advertisements.
In many cases, the software used for browsing websites (web browser) allows cookies to be stored on the user's end device by default. Website users can change their cookie settings at any time. These settings can be changed in particular in such manner as to block the automatic handling of cookies in the web browser settings or inform about their every posting on the website user's device.
Most browsers allow users to control cookies in their preferences settings. Users should read privacy policies of such browsers in order to learn about their relevant cookie policies. Limiting the possibility of setting cookies may deteriorate the overall quality of the use of websites.
If you do not wish to receive cookies, you can change your web browser settings. However, we would like to inform you that limiting the use of cookies may affect some of the functionalities available on the Veneo websites. In particular, we advise that disabling cookies necessary for authentication, security, and preferences will make it difficult to use websites, and in extreme cases may even prevent their use.
In order to manage cookie settings, select the web browser you use from the list below and follow the instructions:
Detailed information on the possibilities and methods of handling cookies is available in the web browser menu, most often in the "Help" section.
XX. Consent to the data processing by cookies
Your data is processed on the basis of consent. Granting consent to the processing of data by cookies is voluntary, and sometimes (e.g. due to logging in to remember the session) necessary. You have the right to rectify, delete, or limit the processing of personal data or the right to object to the processing, as well as the right to lodge a complaint with the supervisory body and the right to transfer your data. You have the right to request access to your personal data, change it as well as delete and withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of the processing which was conducted on the basis of consent prior to its withdrawal.
XXI. From when do this Privacy Policy and Cookies Policy apply
These Privacy Policy and Cookie Policy take effect as of 15 May 2018.
