Privacy policy

This document defines the Privacy Policy rules on the website https://surelikes.com (hereinafter referred to as the “Website”). The Website administrator is VVES Sp. z o.o. with headquarters in Katowice (postal code 40-007) at ul. Uniwersytecka 13, NIP 9542879134, REGON 540152128, KRS 0001137605.

Terms used with capital letters have the meaning given to them in the terms and conditions of this Website.

Personal data collected by the Website Administrator is processed in accordance with applicable privacy laws and regulations, including but not limited to relevant privacy laws in the United States, Canada, and other jurisdictions where our services are provided.

The Website Administrator takes special care to protect the privacy and information provided by the Users of the Website. The Administrator diligently selects and applies appropriate technical measures, including programming and organizational measures, ensuring the protection of processed data, in particular securing data against unauthorized access, disclosure, loss and destruction, unauthorized modification, as well as against processing in violation of applicable laws.

The Website services (in particular the ability to place Orders) are not intended for individuals under 16 years of age. The Personal Data Administrator does not intentionally collect data concerning individuals under 16 years of age.

Personal Data Administrator

The administrator of your personal data is:

VVES Sp. z o.o. with headquarters in Katowice (40-007) at ul. Uniwersytecka 13.

Regarding your personal data, you can contact the Personal Data Administrator via:

• Email: support@surelikes.com
• Mail: Uniwersytecka 13, 40-007 Katowice, Poland

Purposes and Legal Basis for Processing Personal Data

The Personal Data Administrator processes your personal data for the following purposes and scope:

1. To take actions before concluding a contract at your request (e.g., creating an account), i.e., data provided in the registration form on the Website, such as email address and established password, gender; if the Account registration takes place via an external authentication service (e.g., Google+, Facebook), we collect your first and last name, and if you register when ordering Products, we collect your first and last name and data provided for order fulfillment such as shipping address;
2. To provide services requiring the creation of an Account such as: maintaining order history, providing information about the status of order fulfillment, we process your data provided in the Account and when ordering Products;
3. To provide Services that do not require creating an Account and purchasing a Product, i.e., browsing the Website, Product search, we process personal data regarding your activity on the Website, i.e., data regarding Products you view, data regarding your device session, operating system, browser, location and unique ID, IP address;
4. To perform the intermediation agreement (e.g., delivery of ordered Products), we process personal data provided by you when ordering Products, such as name, email address, address data, payment data;
5. For statistics on the use of particular functionalities available on the Website, to facilitate the use of the Website and to ensure IT security of the Website, we process personal data regarding your activity on the Website and the amount of time spent on each subpage on the Website, your search history, location, IP address, device ID, data regarding your web browser and operating system;
6. To establish, pursue and enforce claims and defend against claims in court proceedings and other enforcement authorities, we may process your personal data provided when ordering Products or creating an Account and other data necessary to prove the existence of a claim or which result from a legal requirement, court order or other legal procedure;
7. To consider complaints, grievances and requests and to respond to User questions, we process personal data provided by you in the contact form, complaints, grievances and requests, or to provide answers to questions contained in another form, as well as some personal data provided by you in the Account, as well as data regarding the order of Products and other services provided by us that are the cause of the complaint, grievance or request, and data contained in documents attached to complaints, grievances and requests;
8. For marketing our Products and Services and those of our clients and partners, including remarketing, we process personal data provided by you when creating the Account and updating it, data regarding your activity on the Website including orders that are registered and stored via cookies, and in particular order history, search history, clicks on the Website, login and registration dates, history and your activity related to our communication with you. In the case of remarketing, we use data about your activity to reach you with our marketing communications outside the Website and use external service providers for this purpose. These services consist of displaying our communications on websites other than the Website. Details on this can be found in the Cookies section;

Categories of Relevant Personal Data

The Personal Data Administrator processes the following categories of relevant personal data:

• Contact data;
• Data regarding activity on the Website;
• Data regarding orders on the Website;
• Data regarding complaints, grievances and requests;
• Data regarding marketing services.

Voluntary Provision of Personal Data

Providing your required personal data is voluntary and is a condition for the provision of services by the Personal Data Administrator via the Website.

Data Processing Time

Personal data will be processed for the period necessary to fulfill orders, services, marketing activities, and other services performed for the User. Personal data will be deleted in the following cases:

• When the data subject requests their deletion or withdraws consent;
• When the data subject does not take any action for more than 10 years (inactive contact);
• Upon receiving information that the stored data is outdated or inaccurate.

Some data within the scope of: email address, name and surname, may be stored for a period of subsequent 3 years for evidential purposes, handling complaints, grievances and claims related to services provided by the Website – this data will not be used for marketing purposes.

Data regarding orders of Products and paid services, contests and loyalty programs will be stored for a period of 5 years from the date of order delivery.

Data regarding non-logged-in Users is stored for a time corresponding to the life cycle of cookies saved on their devices or until they are deleted from the User’s device by the User.

Your personal data regarding preferences, behaviors and selection of marketing content may be used as a basis for automated decisions to determine the sales capabilities of the Website.

Recipients of Personal Data

We transfer your personal data to the following categories of recipients:

• Government authorities, e.g., prosecutor’s office, Police, data protection authorities, consumer protection agencies, if they request it from us,
• Service providers we use when operating the Website, e.g., for order fulfillment.

Rights of the Data Subject

Based on applicable privacy laws, you have the right to:

• Request access to your personal data;
• Request correction of your personal data;
• Request deletion of your personal data;
• Request restriction of processing of personal data;
• Object to the processing of personal data;
• Request transfer of personal data.

The Personal Data Administrator, without undue delay – and in any case within one month of receiving the request – will provide you with information on actions taken in connection with your request. If necessary, the one-month period may be extended by two additional months due to the complex nature of the request or the number of requests.

In any case, the Personal Data Administrator will inform you of such an extension within one month of receiving the request, stating the reasons for the delay.

Right of Access to Personal Data

You have the right to obtain from the Personal Data Administrator information whether your personal data is being processed.

If the Administrator processes your personal data, you have the right to:

• Access to personal data;
• Obtain information about the purposes of processing, categories of processed personal data, about recipients or categories of recipients of this data, the planned period of storage of your data or about the criteria for determining this period, about the rights you have under applicable privacy laws and about the right to lodge a complaint with a supervisory authority, about the source of this data, about automated decision-making, including profiling, and about safeguards applied in connection with the transfer of these data outside the United States or Canada;
• Obtain a copy of your personal data.

If you want to request access to your personal data, submit your request to: support@surelikes.com.

Right to Rectify Personal Data

If your personal data is incorrect, you have the right to request the Administrator to immediately correct your personal data.

You also have the right to request the Administrator to complete your personal data.

If you want to request rectification of personal data or its completion, submit your request to: support@surelikes.com.

If you have registered on the Website, you can correct and complete your personal data yourself after logging in to the Website.

Right to Delete Personal Data, the so-called “Right to be Forgotten”

You have the right to request the Personal Data Administrator to delete your personal data when:

• Your personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
• You have withdrawn a specific consent, to the extent that personal data was processed based on your consent;
• Your personal data has been processed unlawfully;
• You have objected to the processing of your personal data for direct marketing purposes, including profiling, to the extent that the processing of personal data is related to direct marketing;
• You have objected to the processing of your personal data in connection with processing necessary for the performance of a task carried out in the public interest or processing necessary for purposes arising from legitimate interests pursued by the Personal Data Administrator or a third party.

Despite the request to delete personal data, the Personal Data Administrator may continue to process your data for the purpose of establishing, pursuing or defending claims, of which you will be informed.

If you want to request the deletion of your personal data, submit your request to: support@surelikes.com.

Right to Request Restriction of Personal Data Processing

You have the right to request restriction of the processing of your personal data when:

• You question the correctness of your personal data – the Personal Data Administrator will restrict the processing of your personal data for a period allowing to check the correctness of this data;
• When the processing of your data is unlawful, and instead of deleting personal data, you request the restriction of the processing of your personal data;
• Your personal data is no longer needed for the purposes of processing, but it is needed by you to establish, assert or defend your claims;
• When you have objected to the processing of your personal data – until it is determined whether the legitimate interests on the part of the Personal Data Administrator override the grounds specified in your objection.

If you want to request restriction of the processing of your personal data, submit your request to: support@surelikes.com.

Right to Object to the Processing of Personal Data

You have the right at any time to object to the processing of your personal data, including profiling, in connection with:

• Processing necessary for the performance of a task carried out in the public interest or processing necessary for purposes arising from legitimate interests pursued by the Personal Data Administrator or a third party;
• Processing for direct marketing purposes.

If you want to object to the processing of your personal data, submit your request to: support@surelikes.com.

Right to Request Data Portability

You have the right to receive from the Personal Data Administrator your personal data in a structured, commonly used machine-readable format and send it to another personal data administrator.

You may also request that the Personal Data Administrator send your personal data directly to another administrator (if technically possible).

If you want to request the transfer of your personal data, submit your request to: support@surelikes.com.

Right to Withdraw Consent

You can withdraw your consent to the processing of your personal data at any time.

Withdrawal of consent to the processing of personal data does not affect the lawfulness of processing based on your consent before its withdrawal.

If you want to withdraw your consent to the processing of your personal data, submit your request to: support@surelikes.com or use the appropriate functionalities in the Account.

Complaint to the Supervisory Authority

If you believe that the processing of your personal data violates applicable privacy laws, you have the right to lodge a complaint with a supervisory authority, in particular in the country of your habitual residence, your place of work, or the place where the alleged violation occurred.

“Cookies” Files

When browsing the Website, “cookies” files are used, hereinafter referred to as Cookies, which are small text information stored on your end device in connection with the use of the Website. Their use is aimed at the proper functioning of the Website.

These files allow identifying the software used by you and customizing the Website individually to your needs.

“Cookies” files usually contain the domain name from which they originate, the time they are stored on the device, and the assigned value.

Security

The “cookies” files we use are safe for your devices. In particular, it is not possible for viruses or other unwanted software or malicious software to enter your devices through “cookies” files.

Types of “Cookies” Files

We use two types of cookies:

• Session Cookies: They are stored on your device and remain there until the end of the browser session. The saved information is then permanently deleted from your device memory. The session cookies mechanism does not allow the collection of any personal data or any confidential information from your device.
• Persistent Cookies: They are stored on your device and remain there until they are deleted. Ending the browser session or turning off the device does not delete them from your device. The persistent cookies mechanism does not allow the collection of any personal data or any confidential information from your device.

Purposes

We also use third-party “cookies” files for the following purposes:

• Website configuration;
• Creating statistics that help understand how Website Users use the websites, which enables improving their structure and content through the Google Analytics analytical tools, the administrator of which is Google Inc based in the USA, Google’s Privacy Policy is available at the following links: http://www.google.com/intl/en/policies/privacy/, http://www.google.com/intl/en/policies/privacy/partners/;
• Determining the User’s profile in order to display matched materials in advertising networks, using the Google AdSense internet advertising tool, the administrator of which is Google Inc. based in the USA, Google’s Privacy Policy is available at the following links: http://www.google.com/intl/en/policies/privacy/, http://www.google.com/intl/en/policies/privacy/partners/;
• Determining the User’s profile in order to display matched materials in advertising networks, using the Google Adwords internet advertising tool, the administrator of which is Google Inc. based in the USA, Google’s Privacy Policy is available at the following links: http://www.google.com/intl/en/policies/privacy/, http://www.google.com/intl/en/policies/privacy/partners/;
• Popularizing the Website using the Facebook.com social networking site, the administrator of which is Facebook Inc. based in the USA or Facebook Ireland based in Ireland, Facebook’s Privacy Policy is available at the following link: https://www.facebook.com/help/cookies/.

To understand the principles of using Cookies, we recommend that you familiarize yourself with the privacy policies of the above-mentioned companies.

Cookies may be used by advertising networks, in particular the Google network, to display advertisements tailored to your preferences. For this purpose, information about how you navigate the network or the time of using the website may be stored.

To view and edit information about your preferences collected by the Google advertising network, you can use the tool available at the link https://www.google.com/ads/preferences/.

Through your web browser settings or through service configuration, you can independently and at any time change the settings for Cookies, specifying the conditions for their storage and access by Cookies to your device. You can change these settings to block the automatic handling of Cookies in your web browser settings or to inform about their placement on your device each time. Detailed information about the possibilities and ways of handling Cookies are available in the settings of your software (web browser).