PRIVACY POLICY

Responsible for the processing of data is:

Hogai Sp. z o. o.
ul. Ksawerów 21, 02-656 Warszawa, hogai@hogai.store

Thank you for visiting our online shop. Protection of your privacy is very important to us. Below you will find extensive information about how we handle your data.

1. Access data and hosting

You may visit our website without revealing any personal information. With every visit on the website, the web server stores automatically only a so-called server log file which contains e.g. the name of the requested file, your IP address, the date and time of the request, the volume of data transferred and the requesting provider (access data), and documents the request. These access data are analysed exclusively for the purpose of ensuring the smooth operation of the website and improving our offer. This serves according to Art. 6 (1) 1 lit. f GDPR the protection of our legitimate interests in the proper presentation of our offer that are overriding in the process of balancing of interests. All access data are deleted no later than one month after the end of your visit on our website.

Hosting

The services for hosting and displaying the website are partly provided by our service providers on the basis of processing on our behalf. Unless otherwise stated in this privacy policy, all access data and all data collected in forms provided for this purpose on this website are processed on their servers. If you have any questions about our service providers and the basis of our cooperation with them, please use the contact option described in this privacy policy.

2. Data processing for the purposes of processing the contract, establishing contact

2.1 Data processing for the purposes of performing the contract

For the purpose of performing the contract (including enquiries regarding the processing of any existing warranty and performance fault claims as well as any statutory updating obligations) in accordance with Art. 6 (1) (b) GDPR, we collect

personal data if you provide it to us voluntarily as part of your order. Mandatory fields are marked as such, as in these cases we necessarily need the data to process the contract and we cannot send the order without their specification. Which data is collected can be seen from the respective input forms.

Further information on the processing of your data, in particular on the forwarding of the data to our service providers for the purpose of order, payment and shipping, can be found in the following sections of this privacy policy. After complete processing of the contract, your data will be restricted for further processing and deleted after expiry of the retention periods under tax and commercial law in accordance with Art. 6 (1) (c) GDPR, unless you have expressly consented to further use of your data in accordance with Art. 6 (1) (a) GDPR or we reserve the right to use data beyond this, which is permitted by law and about which we inform you in this privacy policy.

Merchandise management system

We use merchandise management systems of external service providers for order and contract processing. We engage our service providers on the basis of processing on our behalf. If you have any questions about our service providers and the basis of our cooperation with them, please use the contact option described in this privacy policy.

2.2 Customer account

Insofar as you have given your consent to this in accordance with Art. 6 (1) (a) GDPR by deciding to open a customer account, we will use and store your data for the purpose of opening the customer account as well as for further future orders on our website. Deletion of your customer account is possible at any time and can be done either by sending a message to the contact option described in this privacy policy or via a function provided for this purpose in the customer account. After deletion of your customer account, your data will be deleted unless you have expressly consented to further use of your data in accordance with Art. 6 (1) (a) GDPR or we reserve the right to use data beyond this, which is permitted by law and about which we inform you in this privacy policy.

2.3 Establishing contact

As part of our customer communication, we collect personal data in order to process your enquiries in accordance with Art. 6 (1) (b) GDPR if you voluntarily provide us with this data when contacting us (e.g. via contact form or e-mail). Mandatory fields are marked as such, as in these cases we necessarily need the data to process your enquiry. Which data is collected can be seen from the respective input forms. After your enquiry has been fully processed, your data will be deleted unless you have

expressly consented to further use of your data in accordance with Art. 6 (1) (a) GDPR or we reserve the right to use data beyond this, which is permitted by law and about which we inform you in this privacy policy.

Live-Chat-Tool Userlike

For the purposes of customer communication, we use the live chat tool of Userlike UG (limited), Probsteigasse 44-46, 50670 Cologne, Germany (“Userlike”). This serves to protect our legitimate interests in effective and improved customer communication, which prevail in the context of a balancing of interests, pursuant to Art. 6 (1) (f) GDPR. Userlike acts as a data processor.

3. Data processing for the purposes of shipment

We forward your data to the shipping company within the scope required for the delivery of the ordered goods according to Art. 6 (1) (b) GDPR.

4. Data processing for the purposes of payment

As part of the payment process in our online shop, we work together with these partners: technical service provider, credit institution, payment service provider.

4.1 Data processing for the purposes of transaction processing

Depending on the selected payment method, we forward the data necessary for processing the payment transaction to our technical service providers, who act for us on the basis of processing on our behalf or to the authorised credit institutions or to the selected payment service provider insofar as this is necessary for the payment process. This serves the fulfilment of the contract according to Art. 6 (1) (b) GDPR. In certain cases, payment service providers collect the data required for processing the payment themselves, e.g. on their own website or via technical solution within the ordering process. In this respect, the privacy policy of the respective payment service provider applies. If you have any questions about our payment processing partners and the basis of our cooperation with them, please use the contact option described in this privacy policy.

4.2 Data processing for the purposes of fraud prevention and optimisation of our payment processes

We may forward other data to our service providers, which they use for the purpose of fraud prevention and to optimise our payment processes (e.g. invoicing, processing of

contested payments, accounting support) together with the data necessary to process the payment as our processors.
This serves to safeguard our legitimate interests in fraud prevention or an efficient payment management in accordance with Art. 6 (1) (f) GDPR that are overriding in the process of balancing of interests.

5. Marketing via E-mail

If you subscribe to our newsletter, we will regularly send you our email newsletter based on your consent according to Art. 6 (1) (a) GDPR, using the data required or disclosed by you separately for this purpose.

You can unsubscribe from the newsletter at any time. This can either be done by sending a message to the contact option described in this privacy policy or via a link provided for this purpose in the newsletter. After unsubscribing, we will delete your e- mail address from the list of recipients, unless you have expressly consented to the further use of your data according to Art. 6 (1) (a) GDPR or we have reserved the right to use your data for other purposes that are permitted by law and about which we inform you in this privacy policy.

5.1 Newsletter mailing
5.2 Sending review requests by e-mail

If you have given us your explicit consent to do so during or after placing your order in accordance with Art. 6 (1) (a) GDPR, we will use your e-mail address to request an review of your order via the review system we use. This consent can be withdrawn at any time by sending a message to the contact option described in this privacy policy or via a link provided for this purpose in the review request.

The review requests may also be sent by our service provider Trusted Shops AG Subbelrather Str. 15C, 50823 Cologne (“Trusted Shops”).

In the process, we receive information on the respective status through Trusted Shops (e.g. whether the review request was sent out or received). This is done in accordance with Art. 6 (1) (f) GDPR to fulfill our legitimate interest in receiving information about the review requests in order to make optimizations based on them, if necessary, as well as to fulfill the legitimate interest of Trusted Shops in being able to offer this service.

We and Trusted Shops act as joint controllers in regards to sending review requests and the collection and display of review or status information.

Within the framework of the joint controllership between us and Trusted Shops, please contact Trusted Shops if you have any data protection questions or wish to assert your rights. You can find their contact details here. Further information on data protection can be found in the following link here. Regardless of this, you can also always contact us using the contact option described in this privacy policy. Your inquiry will then, if necessary, be passed on to the party responsible for responding to it.

6. Cookies and further technologies General information

In order to make visiting our website attractive and to enable the use of certain functions, to display suitable products or for market research, we use technologies on various pages, including so-called cookies. Cookies are small text files that are automatically stored on your end device. Some of the cookies we use are deleted after the end of the browser session, i.e. after closing your browser (so-called session cookies). Other cookies remain on your end device and enable us to recognise your browser during your next visit (persistent cookies).

Protection of privacy for terminal devices

When you use our online services, we use technologies that are absolutely necessary in order to provide the telemedia service you have expressly requested. The storage of information in your terminal device or access to information that is already stored in your terminal device does not require consent in this respect.

For functions that are not absolutely necessary, the storage of information in your terminal device or access to information that is already stored in your terminal device requires your consent. Please note that if you do not give your consent, parts of the website may not be available for unrestricted use. Any consent you may have given will remain valid until you adjust or reset the respective settings in your terminal device.

In addition, we use technologies to fulfil the legal obligations, which we are subject to (e.g. to be able to prove consent to the processing of your personal data) as well as for web analysis and online marketing. Further information on this, including the respective legal basis for data processing, can be found in the following sections of this privacy policy.

Any downstream data processing through cookies and other technologies

We use such technologies that are strictly necessary for the use of certain functions of our website (e.g. shopping cart function). These technologies are used to collect and process IP addresses, time of visit, device and browser information as well as

information on your use of our website (e.g. information on your preferences). This serves to safeguard our legitimate interests in an optimised presentation of our offer that are overriding in the process of balancing of interests.

You can find the cookies settings for your browser by clicking on the following links: Microsoft EdgeTM / SafariTM / ChromeTM / FirefoxTM / OperaTM

If you have consented to the use of the technologies in accordance with Art. 6 (1) (a) GDPR, you can withdraw your consent at any time by sending a message to the contact option described in the privacy policy.

How can I configure the cookie settings of my browser?

Each browser is different in the way it manages cookie settings. This is described in the help menu of each browser, which explains how to change your cookie settings. You can find these for each browser under the following links:
Microsoft EdgeTM / SafariTM / ChromeTM / FirefoxTM / OperaTM

What types of cookies are being used?

7. Use of cookies and other technologies

If you have given your consent in accordance with Art. 6 (1) (a) GDPR, we use the following cookies and other third-party technologies on our website. The data collected in this context will be deleted after the relevant purpose has been fulfilled and we have ended the use of the respective technology. You can withdraw your consent at any time with effect for the future. Further information on your withdrawal options can be found in the section “cookies and further technologies”. Further information including the legal basis for data processing can be found within the respective technologies. If you have any questions about our service providers and the basis of our cooperation with them, please use the contact option described in this privacy policy.

7.1 Use of Google services

We use the following technologies of Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). The information automatically collected by Google technologies about your use of our website is usually transferred to a server of Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA and stored there. There is no adequacy decision with respect to the USA by the European Commission. Our cooperation is based on standard data protection clauses adopted by the European Commission. If your IP address is collected using Google technologies, it will be shortened by activating IP anonymisation before being stored on Google’s servers.

Only in exceptional cases will the full IP address be transferred to a Google server and shortened there. Unless otherwise specified for the specific technologies, data processing is based on an agreement concluded for the respective technology between jointly responsible parties in accordance with Art. 26 GDPR. Further information about data processing by Google can be found in Google’s privacy policy.

Google Analytics

For the purpose of website analytics, Google Analytics automatically collects and stores data (IP address, time of visit, device and browser information as well as information on your use of our website), from which usage profiles are created using pseudonyms. Cookies can be used for this purpose. Your IP address will not be merged with other data from Google. The data processing is based on a data processing agreement with Google.

Google Ads

For advertising purposes in the Google search results as well as on the websites of third parties, the so-called Google Remarketing Cookie is used when you visit our website, which automatically enables interest-based advertising through the collection and processing of data (IP address, time of visit, device and browser information as well as information on your use of our website), by means of a pseudonymous cookie ID and on the basis of the pages you visit. Any further data processing only takes place if you have activated the setting “personalised advertising” in your Google account. In this case, if you are logged into Google while visiting our website, Google will use your data together with Google Analytics data to create and define target group lists for cross-device remarketing.

Google Fonts

For the purpose of a uniform presentation of the contents on our website, data (IP address, time of visit, device and browser information) are collected by the script code “Google Fonts”, transmitted to Google and then processed by Google. We have no influence on this subsequent data processing.

7.2 Use of Facebook services Facebook Ads (Ad manager)

We use Facebook Ads to promote this website on Facebook (by Meta) and other platforms. We determine the parameters of the respective advertising campaign. Facebook (by Meta) is responsible for the exact implementation, in particular the

decision on the placement of the ads with individual users. Unless otherwise specified for the individual technologies, data processing is based on an arrangement between joint controllers in accordance with Art. 26 GDPR. The joint controllership is limited to the collection of data and its transmission to Meta Platforms Ireland. The subsequent data processing by Meta Platforms Ireland is not covered by this arrangement.

8. Integration of the Trusted Shops Trustbadge / other widgets

Provided that you have given your consent in accordance with Art. 6 (1) (a) GDPR, Trusted Shops widgets are integrated on this website to display the Trusted Shops services (e.g. Trustmark, collected reviews) and to offer buyers Trusted Shops products after they have placed an order.

The Trustbadge and the services advertised with it are an offer of Trusted Shops AG, Subbelrather Str. 15C, 50823 Cologne (“Trusted Shops”), with whom we are jointly responsible for data protection according to Art. 26 GDPR. Within the scope of this data protection notice, we inform you in the following about the essential contractual contents in accordance with Art. 26 (2) GDPR.

Within the framework of the joint responsibility existing between us and Trusted Shops AG, please preferably contact Trusted Shops using the contact options provided in the privacy policy, if you have any data protection questions and wish to assert your rights. Irrespective of this, however, you can always contact the person responsible of your choice. Your enquiry will then, if necessary, be passed on to the other person responsible for a response.

8.1 Data processing when integrating the Trustbadge/other widgets

The Trustbadge is provided by a US-American CDN provider (content delivery network). An adequate level of data protection is ensured by standard data protection clauses and other contractual measures.

When the Trustbadge is called up, the web server automatically saves a so-called server log file, which also contains your IP address, the date and time of the call-up, the amount of data transferred and the requesting provider (access data) and the call- up. Immediately after the data collection the IP address is anonymised so that the stored data cannot be assigned to you personally. The anonymised data are used in particular for statistical purposes and for error analysis.

8.2 Data processing after order completion

Provided you have given your consent, the Trustbadge accesses order information stored in your terminal equipment (order total, order number, product purchased if applicable) and your e-mail address after the order has been completed. Your e-mail address is hashed using a cryptological one-way function. The hash value is then transmitted to Trusted Shops with the order information in accordance with Art. 6 (1) (a) GDPR.

This serves to verify whether you are already registered for Trusted Shops services. If this is the case, further processing will take place in accordance with the contractual agreement between you and Trusted Shops. If you are not yet registered for the services or do not give your consent to automatic recognition via the Trustbadge, you will subsequently be given the opportunity to register manually for the use of the services or to conclude the insurance as part of your possibly already existing user contract.

For this purpose, the Trustbadge accesses the following information stored in the terminal equipment you use after you have completed your order: Order total, order number and email address. This is necessary so that we can offer you buyer protection. The data is only transmitted to Trusted Shops if you explicitly decide to take out buyer protection by clicking on the correspondingly designated button in the so-called Trustcard. If you decide to use the services, further processing is based on the contractual agreement with Trusted Shops in accordance with Art. 6 (1) (b) GDPR, in order to be able to complete your registration for buyer protection and insure the order, as well as to be able to subsequently send you rating invitations by e-mail if necessary.

Trusted Shops uses service providers in the areas of hosting, monitoring and logging. The legal basis is Art. 6 (1) (f) GDPR for the purpose of ensuring trouble-free operation. Processing may take place in third countries (USA and Israel). An adequate level of data protection is ensured in the case of the USA by standard data protection clauses and further contractual measures and in the case of Israel by an adequacy decision. You can find more information here.

9. Social Media
9.1 Social Plugins by Facebook, Instagram, Pinterest

Social buttons by social networks are used on our website. These are only integrated into the page as HTML links, so that no connection to the servers of the respective provider is established when our website is accessed. If you click on one of the

buttons, the website of the respective social network will open in a new window of your browser. There you can click e.g. the Like or Share button.

9.2 Our online presence on Facebook, Instagram, Pinterest, LinkedIn

If you have given your consent to the respective social media provider in accordance with Art. 6 (1) (a) GDPR, when you visit our online presence on the social media mentioned above, your data will be automatically collected and stored for market research and advertising purposes, from which user profiles are created using pseudonyms. These can be used, for example, to place advertisements within and outside the platforms that presumably correspond to your interests. Cookies are usually used for this purpose. For detailed information on the processing and use of data by the respective social media provider, as well as a contact option and your rights and settings options for the protection of your privacy, please refer to the provider’s privacy policies linked below. Should you still require assistance in this regard, please contact us.

Facebook (by Meta) is provided by Meta Platforms Ireland Ltd, 4 Grand Canal Square, Dublin 2, Ireland (hereafter “Meta Platforms Ireland “) The information automatically collected by Meta Platforms Ireland about your use of our online presence on Facebook (by Meta) is usually transferred to a server of Meta Platforms, Inc., 1 Hacker Way, Menlo Park, California 94025, USA and stored there. There is no adequacy decision for the United States by the European Commission. Our cooperation is based on standard data protection clauses adopted by the European Commission. Data processing in the context of a visit to a Facebook (by Meta) fan page is based on an agreement between joint controllers in accordance with Art. 26 GDPR. Further information (information on Insights data) can be found here.

Instagram (by Meta) is provided by Meta Platforms Ireland Ltd, 4 Grand Canal Square, Dublin 2, Ireland (hereafter “Meta Platforms Ireland “) The information automatically collected by Meta Platforms Ireland about your use of our online presence on Instagram is typically transferred to and stored on a server at Meta Platforms Inc, 1 Hacker Way, Menlo Park, California 94025, USA. There is no adequacy decision for the United States by the European Commission. Our cooperation is based on standard data protection clauses adopted by the European Commission. Data processing in the context of a visit to an Instagram (by Meta) fan page is based on an agreement between joint controllers in accordance with art. 26 DSGVO. Further information (information on Insights data) can be found here.

Pinterest is provided by Pinterest Europe Ltd, Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland (hereafter “Pinterest”). The information automatically

collected by Pinterest about your use of our online presence on Pinterest is usually transferred to and stored on a server of Pinterest, Inc, 505 Brannan St, San Francisco, CA 94107, USA. There is no adequacy decision for the United States by the European Commission. Our cooperation is based on standard data protection clauses adopted by the European Commission.

LinkedIn is provided by LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland (“LinkedIn”). The information LinkedIn automatically collects about your use of our online presence on LinkedIn is generally sent to a server at LinkedIn Corporation, 1000 W. Maude Avenue, Sunnyvale, CA 94085, USA and stored there. There is no adequacy decision for the United States by the European Commission. Our cooperation is based on standard data protection clauses adopted by the European Commission.

10. Contact options and your rights 10.1 Your rights

Being the data subject, you have the following rights according to:

art. 15 GDPR, the right to obtain information about your personal data which we process, within the scope described therein;
art. 16 GDPR, the right to immediately demand rectification of incorrect or completion of your personal data stored by us;

art. 17 GDPR, the right to request erasure of your personal data stored with us, unless further processing is required

to exercise the right of freedom of expression and information; for compliance with a legal obligation;
for reasons of public interest or
for establishing, exercising or defending legal claims;

art. 18 GDPR, the right to request restriction of processing of your personal data, insofar as

the accuracy of the data is contested by you;
the processing is unlawful, but you refuse their erasure;
we no longer need the data, but you need it to establish, exercise or defend legal claims, or
you have lodged an objection to the processing in accordance with art. 21 GDPR;

art. 20 GDPR, the right to receive your personal data that you have provided to us in a structured, commonly used and machine-readable format or to request its transmission to another controller;

art. 77 GDPR, the right to complain to a supervisory authority . As a rule, you can contact the supervisory authority at your habitual place of residence or workplace or at our company headquarters.

Right to object

If we process personal data as described above to protect our legitimate interests that are overriding in the process of balancing of interests, you may object to such data processing with future effect. If your data are processed for direct marketing purposes, you may exercise this right at any time as described above. If your data are processed for other purposes, you have the right to object only on grounds relating to your particular situation.

After you have exercised your right to object, we will no longer process your personal data for such purposes unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

This does not apply to the processing of personal data for direct marketing purposes. In such a case we will no longer process your personal data for such purposes.

10.2 Contact options

If you have any questions about how we collect, process or use your personal data, want to enquire about, correct, restrict or delete your data, or withdraw any consents you have given, or opt-out of any particular data use, please contact us directly using the contact data provided in our supplier identification.

Data protection Officer:

Patrycja Bruź-Soniewicka, ul. Ksawerów 21, 02-656 Warszawa, Poland

gdpr@hogai.store