PRIVACY POLICY
OF THE ONLINE STORE SELLMASTERY.COM
TABLE OF CONTENTS:
GENERAL PROVISIONS LEGAL BASIS FOR DATA PROCESSING PURPOSE, BASIS, AND PERIOD OF DATA PROCESSING IN THE ONLINE STORE RECIPIENTS OF DATA IN THE ONLINE STORE PROFILING IN THE ONLINE STORE RIGHTS OF THE DATA SUBJECT COOKIES IN THE ONLINE STORE AND ANALYTICS FINAL PROVISIONS
GENERAL PROVISIONS
This privacy policy of the Online Store serves as informational, meaning it does not impose obligations on Service Recipients or Customers of the Online Store. The privacy policy primarily includes rules regarding the processing of personal data by the Administrator in the Online Store, including the grounds, purposes, and duration of personal data processing, the rights of individuals whose data is processed, and information on the use of Cookies and analytical tools in the Online Store.
The Administrator of personal data collected through the Online Store is Bożena Smolarek Consultorium Psychologicum with its registered office in Warsaw (registered office address and correspondence address: Ślimaka 48, Apt. 2, 04-862 Warsaw), registered in the Central Register and Information on Economic Activity (CEIDG) under tax identification number (NIP): 9521416736; REGON: 527937925, email address: contact@sellmastery.com, phone number: +48 504964666 – hereinafter collectively referred to as the “Administrator,” also acting as the Service Provider of the Online Store and the Seller.
Personal data in the Online Store is processed by the Administrator in accordance with applicable law, in particular with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons 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) – referred to as “GDPR.” The official text of the GDPR can be found at: http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32016R0679
The use of the Online Store, including making purchases, is voluntary. Similarly, the provision of personal data by users of the Online Store, whether Service Recipients or Customers, is voluntary, with two exceptions: (1) entering into contracts with the Administrator – failure to provide personal data as indicated on the Online Store website and in the Online Store Regulations and this privacy policy, necessary for the conclusion and performance of a Sales Agreement or an agreement for the provision of Electronic Services with the Administrator, will result in the inability to conclude such agreements. Providing personal data is in such cases a contractual requirement, and if the data subject wishes to enter into such agreement with the Administrator, they are obliged to provide the required data. The scope of data required for entering into an agreement is always specified on the Online Store website and in the Online Store Regulations; (2) statutory obligations of the Administrator – providing personal data is a statutory requirement arising from generally applicable laws imposing on the Administrator the obligation to process personal data (e.g., processing data for accounting purposes), and failure to provide such data will prevent the Administrator from fulfilling these obligations.
The Administrator takes special care to protect the interests of individuals whose personal data is processed, and in particular ensures that the data collected by them are: (1) processed lawfully; (2) collected for specified, legitimate purposes and not further processed in a manner incompatible with those purposes; (3) adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed; (4) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; and (5) processed in a manner that ensures appropriate security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.
Taking into account the nature, scope, context, and purposes of processing as well as the risks of varying likelihood and severity for the rights and freedoms of individuals, the Administrator implements appropriate technical and organizational measures to ensure that processing is performed in accordance with the GDPR and to demonstrate compliance. These measures are subject to regular review and update as necessary. The Administrator employs technical measures to prevent unauthorized access to and modification of personal data transmitted electronically.
All terms, expressions, and acronyms used in this privacy policy and starting with a capital letter (e.g., Seller, Online Store, Electronic Service) shall be understood in accordance with their definitions provided in the Online Store Regulations available on the Online Store’s website.
LEGAL BASIS FOR DATA PROCESSING
The Administrator is authorized to process personal data when – and to the extent that – at least one of the following conditions is met: (1) the data subject has given consent to the processing of their personal data for one or more specific purposes; (2) processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract; (3) processing is necessary for compliance with a legal obligation to which the Administrator is subject; or (4) processing is necessary for the purposes of the legitimate interests pursued by the Administrator or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
The processing of personal data by the Administrator requires the existence of at least one of the grounds specified in section 2.1 of the privacy policy. Specific grounds for processing personal data of Service Recipients and Customers of the Online Store by the Administrator are specified in the subsequent section of the privacy policy – concerning the specific purposes of personal data processing by the Administrator.
PURPOSE, BASIS, AND PERIOD OF DATA PROCESSING IN THE ONLINE STORE
Each time, the purpose, basis, period, and recipients of personal data processed by the Administrator result from actions taken by the respective Service Recipient or Customer in the Online Store or by the Administrator.
The Administrator may process personal data within the Online Store for the following purposes, on the bases, and for the periods indicated in the table below:
| Purpose of Data Processing | Legal Basis for Data Processing | Data Retention Period |
|---|---|---|
| Execution of Sales Agreement or agreement for provision of Electronic Service or taking actions at the request of the data subject prior to conclusion of the above agreements | Article 6(1)(b) GDPR (performance of contract) – processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject prior to entering into a contract | Data are kept for the period necessary for the execution, termination, or expiration of the concluded Sales Agreement or agreement for provision of Electronic Service. |
| Direct marketing (e.g., profiling) | Article 6(1)(f) GDPR (legitimate interests of the Administrator) – processing is necessary for purposes of the legitimate interests pursued by the Administrator – involving protecting the interests and good image of the Administrator, their Online Store, and aiming at product sales | Data are kept for the duration of the Administrator’s legitimate interest pursued, but no longer than the limitation period for claims against the data subject arising from the Administrator’s business activities, which is determined by the Civil Code (basic limitation period for claims related to business activities is three years). The Administrator may not process data for direct marketing purposes in case of effective objection by the data subject in this respect. |
| Marketing activities (e.g., sending newsletters) | Article 6(1)(a) GDPR (consent) – the data subject has given consent to the processing of their personal data for receiving marketing information from the Administrator | Data are kept until withdrawal of consent by the data subject for further processing of their data for this purpose. |
| Keeping accounting records | Article 6(1)(c) GDPR (legal obligation) in connection with Article 74(2) of the Accounting Act, i.e., dated 30 January 2018 (Journal of Laws of 2018, item 395, as amended) – processing is necessary for compliance with a legal obligation incumbent on the Administrator | Data are kept for the period required by the provisions of law requiring the Administrator to keep accounting records (5 years, counting from the beginning of the year following the financial year to which the data relate). |
| Establishing, pursuing, or defending claims that may be raised by the Administrator or that may be raised against the Administrator | Article 6(1)(f) GDPR (legitimate interests of the Administrator) – processing is necessary for purposes of the legitimate interests pursued by the Administrator – involving establishing, pursuing, or defending claims that may be raised by the Administrator or that may be raised against the Administrator | Data are kept for the duration of the Administrator’s legitimate interest pursued, but no longer than the limitation period for claims that may be raised against the Administrator (basic limitation period for claims against the Administrator is six years). |
| Using the Online Store website and ensuring its proper functioning | Article 6(1)(f) GDPR (legitimate interests of the Administrator) – processing is necessary for purposes of the legitimate interests pursued by the Administrator – involving operation and maintenance of the Online Store website | Data are kept for the duration of the Administrator’s legitimate interest pursued, but no longer than the limitation period for claims against the Administrator arising from the Administrator’s business activities, which is determined by the Civil Code (basic limitation period for claims related to business activities is three years). |
| Conducting statistics and traffic analysis in the Online Store | Article 6(1)(f) GDPR (legitimate interests of the Administrator) – processing is necessary for purposes of the legitimate interests pursued by the Administrator – involving conducting statistics and traffic analysis in the Online Store for the purpose of improving the functioning of the Online Store and increasing product sales | Data are kept for the duration of the Administrator’s legitimate interest pursued, but no longer than the limitation period for claims against the Administrator arising from the Administrator’s business activities, which is determined by the Civil Code (basic limitation period for claims related to business activities is three years). |
RECIPIENTS OF DATA IN THE ONLINE STORE
For the proper functioning of the Online Store, including the execution of concluded Sales Agreements, the Administrator must use the services of external entities (such as software providers, couriers, or entities handling payments). The Administrator exclusively utilizes services of such data processors who guarantee sufficient implementation of appropriate technical and organizational measures to ensure that the processing complies with the requirements of the GDPR and protects the rights of the individuals whose data is concerned.
Personal data may be transferred by the Administrator to third countries, whereby the Administrator ensures that such transfers will occur to a country providing an adequate level of protection in accordance with the GDPR. In the case of other countries, the transfer will be based on standard data protection clauses. The Administrator ensures that the data subjects have the right to obtain a copy of their data. The Administrator only transfers collected personal data when necessary and to the extent required to achieve the purpose of processing in accordance with this privacy policy.
The transfer of data by the Administrator does not occur in every instance or to all recipients or categories of recipients as indicated in the privacy policy. The Administrator transfers data only when necessary to achieve the specific purpose of processing personal data and only to the extent necessary for its implementation.
Personal data of Service Recipients and Customers of the Online Store may be transferred to the following recipients or categories of recipients:
Carriers / freight forwarders / courier brokers – in the case of a Customer using a digital Product or digital service in the Online Store that involves a course where upon completion, the Customer receives a physical certificate or completion acknowledgment, the Administrator provides the collected personal data of the Customer to the selected carrier, freight forwarder, or intermediary handling shipments on behalf of the Administrator, to the extent necessary to fulfill the delivery of such certificate or course completion acknowledgment to the Customer.
Entities handling electronic payments or payments by credit card – in the case of a Customer using electronic payment methods or credit card payments in the Online Store, the Administrator provides the collected personal data of the Customer to the selected entity handling such payments in the Online Store, on behalf of the Administrator, to the extent necessary to process the payment made by the Customer.
Credit providers – in the case of a Customer using installment payment methods in the Online Store, the Administrator provides the collected personal data of the Customer to the selected creditor handling such payments in the Online Store, on behalf of the Administrator, to the extent necessary to process the payment made by the Customer.
Service providers supplying the Administrator with technical, IT, and organizational solutions enabling the Administrator to conduct business activities, including the Online Store and the Electronic Services provided through it (in particular, providers of computer software for running the Online Store, providers of email and hosting services, and providers of software for managing the company and providing technical support to the Administrator). The Administrator provides the collected personal data of the Customer to the selected service provider acting on its behalf only when necessary and to the extent required to achieve the specific purpose of data processing in accordance with this privacy policy.
Providers of accounting, legal, and advisory services providing support to the Administrator in accounting, legal, or advisory matters (in particular, accounting offices, law firms, or debt collection companies). The Administrator provides the collected personal data of the Customer to the selected provider acting on its behalf only when necessary and to the extent required to achieve the specific purpose of data processing in accordance with this privacy policy.
PROFILING IN THE ONLINE STORE
The GDPR imposes on the Administrator the obligation to inform about automated decision-making, including profiling, as referred to in Article 22(1) and (4) of the GDPR, and – at least in these cases – to provide relevant information on the rules for making such decisions, as well as on the significance and anticipated consequences of such processing for the individuals whose data is concerned. With this in mind, the Administrator provides information in this section of the privacy policy regarding possible profiling.
The Administrator may use profiling in the Online Store for direct marketing purposes, but the decisions made by the Administrator based on profiling do not concern the conclusion or refusal of a Sales Agreement or the possibility of using Electronic Services in the Online Store. The result of profiling in the Online Store may include, for example, granting a discount to a specific person, sending them a discount code, reminding them of unfinished purchases, sending proposals for Products that may match the interests or preferences of that person, or proposing a better price or other conditions compared to the standard offer of the Online Store. Despite profiling, the individual concerned freely decides whether to use the received discount or better conditions and make a purchase in the Online Store.
Profiling in the Online Store involves the automatic analysis or forecast of the behavior of a person on the Online Store’s website, such as adding a specific Product to the cart, browsing a specific Product page in the Online Store, the history of visits to the Online Store, or analyzing the history of previous purchases made in the Online Store. The condition for such profiling is that the Administrator possesses personal data of the individual to subsequently send them, for example, a discount code.
The individual whose data is concerned has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them.
RIGHTS OF THE INDIVIDUAL WHOSE DATA IS CONCERNED
Right of access, rectification, restriction, deletion, or portability – the individual whose data is concerned has the right to request from the Administrator access to their personal data, its rectification, deletion (“right to be forgotten”), or restriction of processing, and has the right to object to processing, as well as the right to data portability. Detailed conditions for exercising these rights are set out in Articles 15-21 of the GDPR.
Right to withdraw consent at any time – the individual whose data is processed by the Administrator based on their consent (under Article 6(1)(a) or Article 9(2)(a) of the GDPR) has the right to withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
Right to lodge a complaint with a supervisory authority – the individual whose data is processed by the Administrator has the right to lodge a complaint with a supervisory authority in the manner and procedure specified in the provisions of the GDPR and Polish law, in particular the Act on the Protection of Personal Data. The supervisory authority in Poland is the President of the Office for Personal Data Protection.
Right to object – the individual whose data is concerned has the right to object at any time, on grounds relating to their particular situation, to the processing of their personal data based on Article 6(1)(e) (public interest or exercise of official authority) or (f) (legitimate interests of the Administrator), including profiling based on these provisions. In such a case, the Administrator may no longer process such personal data unless they demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the individual whose data is concerned, or for the establishment, exercise, or defense of legal claims.
To exercise the rights described in this privacy policy section, you can contact the Administrator by sending a relevant message in writing or by email to the Administrator’s address provided at the beginning of the privacy policy.
COOKIES IN THE ONLINE STORE AND ANALYTICS
Cookies are small text information stored as text files sent by a server and saved on the side of the person visiting the Online Store website (e.g., on the hard drive of a computer, laptop, or memory card of a smartphone – depending on the device used by the visitor of our Online Store). Detailed information about cookies and their history can be found, among others, here: https://en.wikipedia.org/wiki/HTTP_cookie.
Cookies sent by the Online Store website can be categorized according to the following criteria:
By their provider:
Own (created by the Administrator of the Online Store website)
Third-party (created by entities other than the Administrator)
By their storage period on the visitor’s device:
Session cookies (stored until leaving the Online Store website or closing the web browser)
Persistent cookies (stored for a specified period, defined by the parameters of each cookie or until manually deleted)
By the purpose of their use:
Necessary cookies (enabling the proper functioning of the Online Store website)
Functional/preference cookies (allowing customization of the Online Store website according to the preferences of the visitor)
Analytical and performance cookies (collecting information about the usage of the Online Store website)
Marketing, advertising, and social media cookies (collecting information about the visitor of the Online Store website for displaying ads, personalizing ads, measuring effectiveness, and conducting other marketing activities, including on separate websites such as social media platforms or other sites within the same advertising networks as the Online Store)
The Administrator may process data contained in cookies during the use of the Online Store website by visitors for the following specific purposes:
Remembering Products added to the cart to place an Order (necessary cookies)
Remembering data from completed Order Forms or surveys (necessary cookies and/or functional/preference cookies)
Customizing the content of the Online Store website to the individual preferences of the Service Recipient (e.g., regarding colors, font size, page layout) and optimizing the use of the Online Store website (functional/preference cookies)
Remembering the browsing history of the Service Recipient on the Online Store website to individually adjust the displayed Product prices based on whether the Service Recipient visits the Online Store again or for the first time (analytical and performance cookies and/or functional/preference cookies)
Conducting anonymous statistics presenting the usage patterns of the Online Store website (analytical and performance cookies)
Displaying and rendering ads, limiting the number of ad views, ignoring ads that the Service Recipient does not wish to see, measuring the effectiveness of ads, and personalizing ads, i.e., researching the behavioral characteristics of visitors to the Online Store website through anonymous analysis of their actions (e.g., repeated visits to specific pages, keywords, etc.) to create their profile and deliver ads tailored to their predicted interests, including when they visit other websites in the advertising network of Google Ireland Ltd. and Facebook, i.e., Meta Platforms Ireland Ltd. (marketing, advertising, and social media cookies)
In each place where the email address kontakt@sprzedawaj.com appears, replace it with the address contact@sellmastery.com. In each place where the web address www.sprzedawaj.com appears, replace it with the address www.sellmastery.com.
COOKIES IN THE ONLINE STORE AND ANALYTICS
Checking which Cookies (including their duration and provider) are currently sent by the Online Store website in the most popular web browsers is possible as follows:
In Chrome: (1) Click on the padlock icon on the left side of the address bar, (2) go to the “Cookies” tab.
In Firefox: (1) Click on the shield icon on the left side of the address bar, (2) go to either the “Allowed” or “Blocked” tab, (3) click on “Cookies for Cross-Site Tracking,” “Tracking Elements from Social Networks,” or “Content with Tracking Elements.”
In Internet Explorer: (1) Click on the “Tools” menu, (2) go to “Internet Options,” (3) navigate to the “General” tab, (4) go to the “Settings” button, (5) click on “View files.”
In Opera: (1) Click on the padlock icon on the left side of the address bar, (2) go to the “Cookies” tab.
In Safari: (1) Click on the “Preferences” menu, (2) go to the “Privacy” tab, (3) click on “Manage Website Data.”
Regardless of the browser, tools available on websites such as https://www.cookiemetrix.com/ or https://www.cookie-checker.com/ can also be used.
Most web browsers on the market by default accept the storage of Cookies. Everyone has the option to specify the conditions for using Cookies through the settings of their own web browser. This means it’s possible to partially limit (e.g., temporarily) or completely disable the ability to store Cookies—however, in the latter case, it may affect some functionalities of the Online Store (for example, it may prevent proceeding through the Order process via the Order Form due to non-retention of Products in the cart during subsequent Order steps).
Browser settings regarding Cookies are crucial for consenting to the use of Cookies by our Online Store—according to regulations, such consent can also be expressed through browser settings. Detailed information on how to change settings related to Cookies and how to independently delete them in the most popular web browsers is available in the help section of each browser and on the following pages (simply click on the respective link):
Chrome browser
Firefox browser
Internet Explorer browser
Opera browser
Safari browser
Microsoft Edge browser
The Administrator may use Google Analytics, Universal Analytics, and Google Tag Manager services provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) in the Online Store. These services help the Administrator generate statistics and analyze traffic on the Online Store. The data collected within these services is processed to create statistics that aid in managing the Online Store and analyzing traffic. This data is aggregate in nature. By utilizing these services in the Online Store, the Administrator collects data such as sources and mediums of acquiring visitors to the Online Store, their behavior on the website, information about devices and browsers used to visit the site, IP addresses and domains, geographic data, demographic data (age, gender), and interests.
It is possible for individuals to easily block the sharing of their activity information on the Online Store website with Google Analytics—for example, by installing a browser add-on provided by Google Ireland Ltd., available here: https://tools.google.com/dlpage/gaoptout?hl=en.
In relation to the possibility of the Administrator using advertising and analytical services provided by Google Ireland Ltd. in the Online Store, it is noted that full information on the rules for processing data of visitors to the Online Store (including information stored in Cookies) by Google Ireland Ltd. can be found in the privacy policy of Google services available online at: https://policies.google.com/technologies/partner-sites.
The Administrator may use the Facebook Pixel service provided by Meta Platforms Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) in the Online Store. This service helps the Administrator measure the effectiveness of ads, understand the actions taken by visitors to the Online Store, and display personalized ads to these individuals. Detailed information about how the Facebook Pixel works can be found at the following website: https://www.facebook.com/business/help/742478679120153?helpref=page_content.
Management of the Facebook Pixel’s operation is possible through ad settings in one’s account on Facebook.com: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen.
FINAL PROVISIONS
The Online Store may contain links to other websites. The Administrator encourages reviewing the privacy policy established on those other sites after navigating away from the Online Store. This privacy policy applies only to the Administrator’s Online Store.