Privacy Policy | 4 Starlings

PRIVACY POLICY

4STARLINGS.COM

TABLE OF CONTENT:

GENERAL PROVISIONS
LEGAL BASIS FOR DATA PROCESSING
PURPOSE, BASIS AND PERIOD OF DATA PROCESSING ON THE WEBSITE
RECIPIENTS OF DATA IN THE WEBSITE
PROFILING ON THE WEBSITE
COOKIES ON THE WEBSITE AND THE ANALYTICS
FINAL PROVISIONS

1. GENERAL PROVISIONS

1.1. This privacy policy is informative, which means that it is not a source of obligations for Service Users. The privacy policy contains primarily rules regarding the processing of personal data by the Administrator on the Website, including the basics, purposes and period of personal data processing and the rights of data subjects, as well as information on the use of Cookies and analytical tools

1.2. The administrator of personal data collected via the Website is 4STARLINGS LIMITED LIABILITY COMPANY LIMITED PARTNERSHIP with its registered office in Białystok (headquarters address and address for service: ul. Króla Zygmunta Augusta 26, 15-136 Białystok, Poland) entered in the Register of Entrepreneurs of the National Court Register under the number KRS 0000818491; registration court in which the company's documentation is stored: District Court in Białystok, XII Commercial Department of the National Court Register; NIP 9662135465, REGON 385058923, email address: [email protected], telephone number: +48 690800823 - hereinafter referred to as the "Administrator" and being at the same time the Website Service Provider

1.3. Personal data are processed by the Administrator in accordance with applicable law, in particular in accordance with 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) - hereinafter referred to as "GDPR" or "GDPR Regulation". The official text of the GDPR Regulation: http://eur-lex.europa.eu/legal-content/PL/TXT/?uri=CELEX%3A32016R0679

1.4. Using the Website, including signing up for the Newsletter, is voluntary. Similarly, providing personal data related to the Service User is voluntary, with two exceptions: (1) entering into contracts with the Administrator - failure to provide, in cases and to the extent indicated on the Website and this privacy policy, personal data necessary to conclude and perform the contract for the provision of Electronic Services with the Administrator results in the inability to conclude such contract. Providing personal data is in this case a contractual requirement and if the data subject wants to conclude a given agreement with the Administrator, he or she is obliged to provide the required data. Each time, the scope of data required to conclude a contract is indicated previously on the Website of the Website and in this privacy policy ; (2) the Administrator's statutory obligations - providing personal data is a statutory requirement resulting from the generally applicable provisions of law imposing an obligation on the Administrator to process personal data (e.g. data processing for the purpose of keeping tax or accounting books) and failure to provide it will prevent the Administrator from performing these obligations.

1.5. The Administrator uses special diligence to protect the interests of persons to whom the personal data processed by him relates, and in particular is responsible and ensures that the data collected by him are: (1) processed in accordance with the law; (2) collected for specified, legitimate purposes and not subjected to further processing incompatible with those purposes; (3) factually correct and adequate in relation to the purposes for which they are processed; (4) stored in a form that allows identification of the persons they concern, no longer than necessary to achieve the purpose of processing, and (5) processed in a way that ensures adequate security of personal data, including protection against unauthorized or unlawful processing and accidental loss, destruction or damage by appropriate technical or organizational measures.

1.6. Taking into account the nature, scope, context and purposes of processing, as well as the risk of violation of the rights or freedoms of natural persons of different probability and severity of threat, the Administrator implements appropriate technical and organizational measures so that the processing takes place in accordance with this Privacy Policy and to be able to demonstrate it. Those measures shall be reviewed and updated where necessary. The administrator uses technical measures to prevent the acquisition and modification by unauthorized persons of personal data sent electronically.

1.7. Definitions:
1.7.1. NEWSLETTER - Electronic Service, electronic distribution service provided by the Service Provider via e-mail, which allows all users to automatically receive periodic contents of subsequent editions of the newsletter that contains product information, news and special offers available on the Website.
1.7.2. WEBSITE - the Service Provider's website available at: www.4starlings.com. 1.7.3. SERVICE PROVIDER – 4STARLINGS LIMITED LIABILITY COMPANY LIMITED PARTNERSHIP with its registered office in Białystok (headquarters address and address for service: ul. Króla Zygmunta Augusta 26, 15-136 Białystok, Poland) entered in the Register of Entrepreneurs of the National Court Register under the number KRS 0000818491; registration court in which the company's documentation is stored: District Court in Białystok, XII Commercial Department of the National Court Register; NIP 9662135465, REGON 385058923, email address: [email protected], telephone number: +48 690800876.
1.7.4. ELECTRONIC SERVICE - a service provided electronically by the Service Provider to the User through the Website.
1.7.5. USER (SERVICE RECIPIENT) - (1) a natural person with full legal capacity, and in the cases provided for by the generally applicable rules also a natural person with limited legal capacity; (2) a legal person; or (3) an organisational unit without legal personality, which is granted a legal capacity by the law – which has entered or intends to enter into the contract for the provision of Electronic Services with the Service Provider.

2. LEGAL BASIS FOR DATA PROCESSING

2.1. The administrator is entitled to process personal data in cases where - and to the extent that- at least one of the following conditions is met: (1) the data subject has consented to the processing of his/her personal data for one or more specific purposes; (2) processing is necessary for the performance of a contract to which the data subject is a party or to take action at the request of the data subject before the conclusion of the contract; (3) processing is necessary to fulfill the legal obligation incumbent on the Administrator; or (4) processing is necessary for purposes arising from legitimate interests pursued by the Administrator or by a third party, except for situations where the interests or fundamental rights and freedoms of the data subject, requiring personal data protection, prevail over these interests, in particular when the data subject is a child.

2.2. The processing of personal data by the Administrator requires at least one of the grounds indicated in point 2.1 of the privacy policy. The specific grounds for processing personal data of the Users Customers by the Administrator are indicated in the next section of the privacy policy - in relation to a given purpose of processing personal data by the Administrator.

3. PURPOSE, BASIS AND PERIOD OF DATA PROCESSING ON THE WEBSITE

3.1. Each time the purpose, basis and period as well as the recipients of personal data processed by the Administrator result from actions taken by a given User on the Website or by the Administrator.

3.2. The Administrator may process personal data as a part of the Website for the following purposes, on the basis of and during the periods indicated in the table below:

Purpose of data processing	Legal grounds for data processing	Data retention period
Performance of the contract for the provision of Electronic Services or taking action at the request of the data subject before concluding the above-mentioned contract	Article 6 paragraph 1 point b) of GDPR Regulation (performance of the contract) - processing is necessary to perform the contract to which the data subject is a party or to take action at the request of the data subject before concluding the contract	The data are stored for the period necessary to perform, terminate or otherwise expire the concluded contract for the provision of Electronic Services.
Direct marketing	Article 6 paragraph 1 point f) of GDPR Regulation (legitimate interest of the administrator) - processing is necessary for purposes arising from the legitimate interests of the Administrator - consisting in taking care of the interests and good image of the Administrator	The data are stored for the duration of the legitimate interest pursued by the Administrator, but no longer than for the period of limitation of the Administrator's claims against the data subject due to the Administrator's business activities. The administrator may not process data for the purpose of direct marketing in the event of effective objection in this respect by the data subject
Marketing	Article 6 paragraph 1 point a) of GDPR Regulation (consent) - the data subject has consented to the processing of his/her personal data for marketing purposes by the Administrator subject.	The data are stored until the data subject withdraws his/her consent for further processing of his/her data for this purpose.
Determining, investigating or defending claims that may be raised by the Administrator or which may be raised against the Administrator	Article 6 paragraph 1 point f) of GDPR Regulation (legitimate interest of the administrator) - processing is necessary for purposes resulting from the legitimate interests of the Administrator - consisting in establishing, investigating or defending claims that may be raised by the Administrator or which may be raised against the Administrator	The data are stored for the duration of the legitimate interest pursued by the Administrator, but no longer than for the period of limitation of claims that may be raised against the Administrator.
Using the Website and ensuring its proper operation	Article 6 paragraph 1 point f) of GDPR Regulation (legitimate interest of the administrator) - processing is necessary for purposes resulting from the legitimate interests of the Administrator - consisting in running and maintaining the Website	The data are stored for the duration of the legitimate interest pursued by the Administrator, but no longer than for the period of limitation of the Administrator's claims against the data subject due to the Administrator's business activities.
Keeping statistics and analyzing traffic on the Website	Article 6 paragraph 1 point f) of GDPR Regulation (legitimate interest of the administrator) - processing is necessary for purposes resulting from the legitimate interests of the Administrator - consisting of keeping statistics and analyzing traffic on the Website in order to improve the functioning of the Website	The data are stored for the duration of the legitimate interest pursued by the Administrator, but no longer than for the period of limitation of the Administrator's claims against the data subject due to the Administrator's business activities.

4. RECIPIENTS OF DATA ON THE WEBSITE

4.1. For the proper functioning of the Website, including for the implementation of concluded contracts for the provision of Electronic Services, it is necessary for the Administrator to use the services of external entities (such as e.g. software supplier). The Administrator uses only the services of such processors who provide sufficient guarantees to implement the appropriate technical and organizational measures, so that the processing meets the requirements of the GDPR Regulation and protects the rights of the data subjects.

4.2. The transfer of data by the Administrator does not take place in each case and not to all recipients or categories of recipients indicated in the privacy policy – the Administrator provides data only when it is necessary for the purpose of processing personal data and only to the extent necessary to achieve it.

4.3. Personal data of the Users may be transferred to the following recipients or categories of recipients:

4.3.1. service providers providing the Administrator with technical, IT and organizational solutions enabling the Administrator to conduct business activities, including Electronic Services provided through it (in particular, the software supplier for running the, the email and hosting provider and the management and technical support software provider) - the Administrator provides the collected personal data of the Customer to the selected supplier acting on his behalf only in the case and to the extent necessary to implement the given purpose of data processing in accordance with this privacy policy.

4.3.2. providers of accounting, legal and advisory services providing the Administrator with accounting, legal or advisory support (in particular an accounting office, law firm) – the Administrator provides the collected personal data of the User to the selected supplier acting on his behalf only in the case and to the extent necessary to implement the given the purpose of data processing in accordance with this privacy policy.

4.3.3. providers of social network plugins placed on the Website, scripts and other similar tools enabling the browser of a person visiting the Website to download content from the suppliers of the mentioned plugins and for this purpose providing the suppliers with the personal data of the visitor, including:
1. Facebook Ireland Ltd. – The administrator uses the Facebook social plugins on the Online Store website (e.g. the Like button, Share or logging in using Facebook login details) and therefore collects and shares the personal data of the Service Recipient using the website for Facebook Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland) to the extent and in accordance with the privacy principles available here: https://www.facebook.com/about/privacy/ (these data include information on activities on the Online Store website - including information about the device, visited websites, purchases, displayed ads and how one uses the services - regardless of whether the Service User has a Facebook account and is logged in to Facebook).

5. PROFILING IN THE ONLINE STORE

5.1. The GDPR Regulation requires the Administrator to inform about automated decision- making, including profiling, as referred to in art. 22 paragraph 1 and 4 of the GDPR Regulation, and - at least in these cases - relevant information about the rules of making these decisions, as well as about the significance and anticipated consequences of such processing for the data subject. With this in mind, the Administrator provides information on possible profiling in this section of the privacy policy.

5.2. The Administrator may use profiling for direct marketing purposes on the Website, but the decisions taken on the basis of it by the Administrator do not relate to the possibility of using Electronic Services on the Website. The effect of using profiling on the Website may be e.g. granting a given person a discount, sending them a discount code, reminding about unfinished purchases, sending a Product proposal that may correspond to the interests or preferences of a given person, or offering better conditions compared to the standard offer of the Online Store. Despite profiling, a given person makes a free decision whether they want to take advantage of …

5.3. Profiling on the Website is based on the automatic analysis or forecast of a given person's behaviour on the Website, e.g. by browsing the page of a specific Product.

5.4. The person to whom the data relate (the data subject) has the right not to be subject to a decision which is based solely on automated processing, including profiling, and that has legal effects or substantially affects the person in a similar way.

6. COOKIES IN THE WEBSITE AND THE ANALYTICS

6.1. Cookies are small text information in the form of text files, sent by the server and saved on the side of the person visiting the Website (e.g. on the hard disk of a computer, laptop or on the smartphone's memory card - depending on which device a user visiting our Online Store is using). Detailed information about Cookies as well as the history of their creation can be found among others here: https://en.wikipedia.org/wiki/HTTP_cookie.

6.2. Cookies files that can be sent by the Online Store website can be divided into different types, according to the following criteria:

Due to their supplier: :

1) own (created by the Administrator's website) and

2) belonging to third parties / entities (other than the Administrator)

Due to their storage period on the device of the person visiting the Website: :

1) session (stored until turning off the web browser) and

2) permanent (stored for a specified period, defined by the parameters of each file or until manually deleted)

Due to the purpose of their use: :

1) necessary (enabling the proper functioning of the Website),

2) functional / preferential (enabling adjustment of the Website to the preferences of the visitor of the website),

3) analytical and performance (collecting information on how one uses the Website),

4) marketing, advertising and related to social networking (collecting information about a person visiting the Website in order to display personalized advertising and conducting other marketing activities, including websites separate from the Website, such as social networking websites).

6.3. The administrator may process the data contained in cookies when visitors use the Website for the following specific purposes:

The purposes of using Cookies in the Administrator's Website	remembering Products added to the cart to place an Order (necessary Cookies)
	adapting the content of the Website to the individual preferences of a Service Recipient (e.g. regarding colours, font size, page layout) and optimizing the use of Website pages (functional / preferential Cookies)
	keeping anonymous statistics showing how one uses the Website (statistical Cookies)
remarketing, i.e. research on the characteristics of the behaviour of visitors to the Website by anonymous analysis of their activities (e.g. repeated visits to specific pages, keywords, etc.) in order to create their profile and provide them with advertisements tailored to their anticipated interests, also when they visit other websites in the Google Ireland Ltd. and Facebook Ireland Ltd. advertising networks (marketing, advertising and related to social networking Cookies)

6.4. Checking in the most popular web browsers which Cookies (including the period of operation of Cookies and their provider) are sent at a given moment by the Online Store website is possible as follows:

In Chrome: : (1) in the address bar, click the padlock icon on the left, (2) go to the "Cookies" tab.	In Firefox: : (1) in the address bar, click the shield icon on the left, (2) go to the "Allowed" or "Blocked" tab, (3) click the "Tracking cookies between websites", "Tracking elements of social networking sites" or "Content with tracking elements"	In Internet Explorer: : (1) click the "Tools" menu, (2) go to the "Internet options" tab, (3) go to the "General" tab, (4) go to the "Settings" tab, (5) click the "View files" field
In Opera: : (1) in the address bar, click the padlock icon on the left, (2) go to the "Cookies" tab.	In Safari: : (1) click the "Preferences" menu, (2) go to the "Privacy" tab, (3) click the "Manage website data" field	Regardless of the browser, using tools available e.g. at: : https://www.cookiemetrix.com/ lub: https://www.cookie-checker.com/

6.5. The first time the User visits the Website, we ask them to agree to the use of optional cookies, i.e. cookies that are not necessary for the proper functioning of the website (by clicking on the "Ok, I understand" box). Everyone has the possibility to specify the conditions for the use of cookies using the settings of their own web browser. This means that you can, for example, partially limit (e.g. temporarily) or completely disable the option of saving Cookies

7.6. The web browser settings for Cookies are important from the point of view of the consent to the use of Cookies by our Online store - in accordance with law, such consent may also be expressed through the web browser settings. Detailed information on changing the settings for Cookies and their self removal in the most popular web browsers are available in the help section of the web browser and on the following pages (just click on the link):

in Chrome

in Firefox

in In t ernet Explorer

in Opera

in Safari

in Microsoft Edge

6.7. The administrator may use the Google Ads, Google Analytics, Universal Analytics services provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) and the Hotjar service provided by Hotjar Limited (Level 2, St Julian's Business Centre, 3, Elia Zammit Street, St Julian's STJ 1000, Malta) on the Website. These services help the Administrator keep statistics and analyze traffic on the Website. The collected data are processed as a part of the above-mentioned services to generate statistics helpful in administering the Website and analyzing traffic on the Website. These data are aggregated. The Administrator, using the above services on the Website, collects such data as sources and medium of acquiring visitors to the Website and how they behave on the Website, information on the devices and browsers from which they visit the website, IPs and domains, geographical data and demographic data (age, gender), as well as their interests.

6.8. It is possible for a person to easily block transferring to Google Analytics the information about his/her activity on the Website - for this purpose, for example, you can install the browser add-on provided by Google Ireland Ltd. available here: https://tools.google.com/dlpage/gaoptout?hl=en.

6.9. The Administrator may use the Facebook Pixel service provided by Facebook Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) on the Website. This service helps the Administrator measure the effectiveness of advertisements and find out what actions are taken by visitors of the Website, as well as display tailored ads to these people. Detailed information on the operation of Facebook Pixel can be found at the following Internet address: https://www.facebook.com/business/help/742478679120153?helpref=page_content.

6.10. Managing the operation of Facebook Pixel is possible through the settings of ads in your account on Facebook.com: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen

7. FINAL PROVISIONS

7.1. The Website may contain links to other websites. The Administrator encourages you to, once you navigate to the other pages, familiarize yourself with the privacy policies enforced therein. This privacy policy applies only to this Website.