1. DEFINITIONS
   1.1 Administrator - FRUNZE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ with seat in Kraków, company entered in the National Court Register at the District Court in Kraków under KRS number 0001088448, with authorized capital PLN 50,000, NIP 6762662783
   REGON 527800250.
   1.2 Personal data - all information about a natural person that is identified or can be identified using one or more factors characteristic of physical identity, including device IP address, location data, Internet identifier and information collected using cookies and other similar technologies.

   1.3 RODO - Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and on the repeal of Directive 95/46/EU.

   1.4 Website - a website operated by the Administrator at lunfix.co.uk.

   1.5 User is any natural person who visits the Site or uses one or more services or functions described in the Privacy Policy.

   COLLECTION OF PERSONAL DATA
   2.1 The administrator collects the personal data of the users of the Site in the amount necessary for the provision of certain services offered, as well as information about the User's activity on the Site. The main method of data collection is voluntary form filling.

   2.2 Users' personal data is collected in case of

   2.2.1 account registration on the Site;

   2.2.2 placing an order on the Site.

   2.3 When registering an account on the Site, the User sets an individual password to access his account. The user can change the password later.

   2.4 Additional information may be collected during use of the frunze.pl Portal, including: IP address assigned to the User's computer or external IP address of the Internet provider, domain name, browser type, access time, type of operating system.

   2.5 Navigation data may also be collected from Users, including information about the links and links they click on or other actions they take on the Website.

   2.6 The Website also operates an automated system for monitoring the behavior of Users and adapting content to the interests of Users. This system is integrated into the Website and any user can object to it at any time.

   PURPOSES AND LEGAL GROUNDS OF DATA PROCESSING
   3.1 In the case of registering an account on the Site, the User's data is used for the purpose of providing services related to the maintenance and functioning of the account on the Site.

   3.2 In order to fulfill the order. The provision of personal data is necessary for the Service Provider to provide electronic services on the Website or to conclude a Contract for the sale of goods.

   3.3 To process orders made without user registration.

   3.4 To fulfill the Administrator's legal obligations arising, in particular, from tax and accounting legislation.

   3.5 For the purpose of possible establishment, presentation or defense of claims.

   3.6 When making a purchase on the Website, personal data may be transferred, depending on the User's choice, to the following entities for the purpose of delivering the ordered goods

   3.6.1 to the courier company DPD Polska Sp. z o. o. located in Warsaw

   3.6.2 InPost Paczkomaty Sp. z o. o. located in Krakow, which provides delivery and maintenance of the mailbox system (Paczkomaty);

   3.6.3 Poczta Polska SA Warsaw.

   3.6.4 "RUCH" SA, located in Warsaw, which provides delivery services to kiosks and press salons of the "RUCH" network.

   3.7 In the event that the Client chooses to pay through the PayU system, his personal data is transferred to the extent necessary for making payments to the company PayU SA, located in Poznań (60-166), at ul. Grunwaldska 182, registered in the register of entrepreneurs maintained by the District Court of Poznań - Nowe Misto and Wilda in Poznań, 8th commercial department of the National Court Register under the number KRS 0000274399.

   3.8 For analytical, statistical and marketing purposes (recommendation system, marketing automation ).

   The legal basis for the processing of personal data for the above purposes is Article 6(1)(a) of REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 27, 2016 on the protection of natural persons in connection with the processing of personal data and on free movement of such data and on the repeal of Directive 95/46/W ("RODO") L119/40 EN Official Journal of the European Union 4.5

INFORMATION ABOUT COOKIE FILES
4.1 The frunze.pl website uses small files, so-called cookies, which are stored in the memory of the User's device used to view the site (for example, PC, laptop, tablet, PDA, mobile phone). Once saved, these files are associated with the server or servers, providing appropriate access to them.

4.2 The Administrator uses three types of "cookies": "session", "permanent" and "analytical":
4.2.1 "Session" "cookies" are temporary files that are stored on the User's terminal equipment until the User logs out of the system (leaving the Site)
4.2.2 "Permanent" "cookies" are stored on the User's terminal equipment for the time specified in the "cookies" parameters or until they are deleted by the User.
4.2.3 "Analytical" "cookies" allow to better understand how the User interacts with the content of the Site, to better organize its layout. "Analytical" "cookies" collect information about the User's use of the Site, the type of page from which the User was redirected, as well as the number of visits and the duration of the User's stay on the Site. This information does not record specific personal data of the User, but is used to compile statistics on the use of the Site.
4.3 The Administrator uses its own cookies for

4.3.1 to authenticate the User on the Site and ensure the User's session on the Site (after logging in), so that the User does not need to re-enter the login and password on each sub-page of the Site

4.3.2 analysis and research, as well as audience audit, in particular for the creation of anonymous statistical data that help to understand how the User uses the frunze.pl Site, which allows to improve its structure and content.

4.4 The administrator uses external cookies for the purpose

4.4.1 of collecting general and anonymous statistical data using the analytical tools of Google Analytics (administrator of external cookies: Google Inc. with headquarters in the USA)

4.4.2 to promote To the site through the social network facebook.com (administrator of external cookies: Facebook Inc with headquarters in the USA or Facebook Ireland with headquarters in Ireland);

4.5 By changing the settings of the software used to view the lunfix.co.uk Site and its subsites, the User can determine the conditions of storage and access to cookies used by the Site and its subsites, and, in particular, can completely disable their use . In order to change the settings related to the processing of cookies, the User must adjust the settings of the web browser used to view the website frunze.pl and its subpages. Information on this can be obtained from the technical support service of such software (web browser) or by contacting its supplier.

PERIOD OF PERSONAL DATA PROCESSING
5.1 The period of data processing by the Administrator depends on the type of service provided and the purpose of processing. As a rule, the data is processed during the period of service provision or order processing, until the consent given is withdrawn or until the effective objection to the data processing in cases where the legal basis of the data processing is the legitimate interest of the Administrator.

5.2 The period of data processing may be extended if the processing is necessary for the establishment and investigation of possible claims or defense against them, and thereafter only in the case and to the extent provided by law. At the end of the processing period, the data must be permanently deleted or anonymized.

RIGHTS OF USERS
6.1 The right to receive information about the processing of personal data.

6.2 The right to receive a copy of data

6.3 The right to change personal data.

6.4 Right to data deletion

6.5 Right to restriction of processing

6.6 Right to data portability

6.7 Right to object to processing for marketing purposes

6.8 Right to object to other processing purposes

6.9 Right to withdraw consent

6.10. the right to appeal - if the processing of personal data is considered to be in violation of RODO or other data protection legislation, the data subject may file a complaint with the Head of the Data Protection Authority.

6.11. A request to exercise the rights of data subjects can be submitted by e-mail to: biuro@frunze.pl. The Administrator may refuse to delete the User's data if the User has violated the current Regulations and data retention is necessary to clarify the circumstances and establish responsibility, in particular, for the Administrator to present claims to the relevant User.

SECURITY OF PERSONAL DATA
7.1 Personal data collected by the Administrator using the Website are processed in accordance with Article 6(1)(a) of REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 27, 2016 on the protection of natural persons in on the processing of personal data and on the free movement of such data and on the repeal of Directive 95/46/W ("RODO") L119/40 EN Official Journal of the European Union 4.5.2016

7.2 The administrator must carry out risk analysis on an ongoing basis to ensure that personal data is processed by the Administrator in a secure manner - ensuring, in particular, access to data only to authorized persons and only to the extent necessary for the performance of their tasks. The administrator guarantees that all operations with personal data are registered and performed only by authorized employees and associated persons.

7.3 The administrator has appointed a data protection officer who can be contacted at the e-mail address: biuro@frunze.pl for any matter related to the processing of personal data.

The privacy policy is reviewed on an ongoing basis and updated as necessary.

For questions related to the Privacy Policy, please contact the address: buiro@frunze.pl