§ 1. GENERAL PROVISIONS

1. The administrator and owner of the https://noyopharm.com website is Noyo Pharm Spółka z ograniczoną odpowiedzialnością with its registered office in Warsaw, at ul. Marywilska 60 lok. 24, 03-042 Warsaw, entered in the Register of Entrepreneurs of the National Court Register under the number KRS: 0001008012, with the NIP number: 5242957810 and REGON number: 523922660, registration files kept by the District Court for the Capital City of Warsaw in Warsaw, 14th Commercial Division of the National Court Register.
2. This privacy policy contains information regarding the processing of personal data that you may share with us when using the online shop and the use of cookies in the online shop.
3. The privacy policy is for information purposes only, which means that it is not a source of obligations for customers of the online shop and the application (it is not a contract or terms and conditions).
4. Words, phrases and abbreviations in the privacy policy beginning with a capital letter (e.g. seller, order form, newsletter, electronic service) should be understood according to their definition in the online shop regulations available in the online shop.
5. Detailed information on the processing of specific personal data is provided each time it is collected in an information clause that is clearly and easily accessible. This includes, in particular, information on the purpose and legal basis of the processing of personal data, the period of storage and the recipients to whom the data is disclosed.
6. The controller shall take all necessary measures to ensure that its partners, subcontractors and other cooperating entities guarantee the application of appropriate security measures whenever they process personal data on behalf of the controller. The administrator conducts ongoing risk analysis to ensure that personal data is processed by him in a secure manner - ensuring, above all, that only authorised persons have access to the data and only to the extent that it is necessary for the performance of their tasks.

§ 2 PERSONAL DATA CONTROLLER AND CONTACT DETAILS

1. The controller of personal data collected via:
   1. the online store (including the use of cookies or similar technology) obtained based on the customer's online activity,
   2. other channels of communication with the customer, e.g. call centre

is Noyo Pharm Spółka z ograniczoną odpowiedzialnością with its registered office in Warsaw, at ul. Marywilska 60 lok. 24, 03-042 Warsaw, entered in the Register of Entrepreneurs of the National Court Register under KRS number: 0001008012, with NIP number: 5242957810 and REGON number: 523922660, registration files kept by the District Court for the Capital City of Warsaw in Warsaw, 14th Commercial Division of the National Court Register.

2. If:
   1. you want to contact the administrator in matters regarding personal data protection,
   2. you have questions about the data or comments regarding this policy,
   3. if you want to exercise your rights regarding your data processed by the administrator as their administrator, you can contact us by email at the contact details indicated above.
3. In matters related to the protection of personal data, you can contact:
   1. by e-mail: [email protected]
   2. by phone: +48 512 594 333 (Mon-Fri 8:00 a.m. – 4:00 p.m.), charged as a standard call (according to the relevant operator's price list).

§ 3. WHAT PERSONAL DATA IS PROCESSED BY THE CONTROLLER

1. Personal data is information relating to an identified or identifiable natural person. An identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. This includes the following information: IP address, form of address, first and last name, address, email address, telephone number.
2. We process personal data of:
   1. online shop users, including those with an account,
   2. customers,
   3. business partners,
   4. newsletter subscribers,
   5. persons who have given their consent to marketing communication,
   6. contact persons, but also persons who have made their personal data available to the controller through other communication channels, i.e.: the website https://www.instagram.com/ and https://www.facebook.com (including mobile phone applications), the operating principles of which are based on the regulations made available in particular at https://www.facebook.com/legal/terms, provided respectively by Facebook Inc. or Facebook Ireland Limited (hereinafter also referred to as: ‘Facebook’). The rules for the protection and use of personal data by Facebook and Instagram are available, for example, at: https://www.facebook.com/policy.php. The administrator has no influence on the content of Facebook's legal regulations, including those regarding personal data.

§ 4. SCOPE, PURPOSE, LEGAL BASIS AND PERIOD OF PROCESSING OF THE COLLECTED DATA

1. Personal data is processed by the administrator on the website in order to enable the use of the online store's functionality, including automatically when using the website, i.e. for the purpose of:
   1. to deliver and display content in the online shop – for this purpose, we process personal data in the form of: IP address, cookies; we process data on the basis of Article 6(1)(f) of the GDPR – the legitimate interest of the controller is to run an online shop,
   2. provision of the account service – for this purpose, we process personal data in the form of: email address, password, IP address, cookies, name and surname, we process data on the basis of Article 6(1)(b) of the GDPR; data for this purpose will be processed no longer than for the period of providing the account service,
   3. conclusion of a contract via the online shop - for this purpose, we process personal data in the form of: IP address, cookies, email address, first and last name, address data (street, house number, city including postal code, country), invoice data, payment data, telephone number, order number or other data provided by the service provider on the website or when contacting the customer; we process the data on the basis of Art. 6(1)(b) GDPR; the data will be processed for this purpose for no longer than 6 years.
   4. fulfilment of the controller's obligations as a seller and service provider - for this purpose, the first name, surname, order data, payment data, e-mail, telephone, street address, house number, city with postcode, country, bank account number, data for issuing an invoice or other document, e.g. tax identification number, personal identification number are processed; we process the data on the basis of Article 6(1)(c) of the GDPR - in particular with regard to obligations arising from tax law; the data will be processed for this purpose for a period not exceeding 5 years, counting from the date of the last order or service provision. 6(1)(c) of the GDPR – in particular with regard to obligations arising from tax law; data for this purpose will be processed for a period not exceeding 5 years from the end of the calendar year in which the tax payment deadline related to the contract concluded with the administrator expired.
   5. the administrator sending the ordered newsletter to the e-mail address indicated by the customer, as well as commercial information to the indicated communication channels [email, sms, telephone] - for this purpose, we process contact details, email address, telephone number, order data, first name, surname, address (street, house number, city and postcode), IP address, cookies, order data and result data - for this purpose, we process personal data on the basis of consent given in this respect pursuant to Article 6(1)(a) GDPR; data for this purpose will be processed for a period not exceeding 5 years.
   6. for statistical and analytical purposes, to customise the website to your preferences - based on consent pursuant to Article 6(1)(a) GDPR - for this purpose, we process personal data using the tools and cookies described in this privacy policy on the basis of consent given in this respect pursuant to Article 6(1)(a) of the GDPR; data will be processed for this purpose for a maximum period of 12 months.
   7. for the purpose of pursuing the legitimate interests of the personal data controller pursuant to Article 6(1)(f) of the GDPR, which are:
      • the fulfilment of complaint obligations regarding the online shop, the handling of complaints regarding products,
      • the operation and functioning of the online shop and ensuring the security of its use, including the disclosure of fraud and the performance of analyses, statistics, surveys, and satisfaction surveys,
      • preparing and presenting advertisements and offers tailored to the interests and needs of the data subjects and receiving commercial information, in particular the sending by the controller of the ordered newsletter to the e-mail address provided by the customer;
      • for the purpose of establishing, defending and pursuing claims, for data archiving.

The data will be processed for this purpose for a period not exceeding 6 years.

2. User activity in the online shop, including personal data, is recorded in system logs (a chronological record of electronic data containing information about events and activities related to the online shop used to provide electronic services by the administrator). The information collected in the logs is processed on the basis of the legitimate interest of the administrator (Article 6(1)(f) of the GDPR) for a period of up to 12 months, primarily for purposes related to the operation of the online store, and is processed for service, technical, analytical, statistical and IT security and management purposes.
3. In all other respects justified by the purposes of the processing, personal data will be stored for as long as there is a legal basis for the processing, unless applicable law requires a longer storage period, e.g. for use in legal proceedings to which the data subject and the controller are parties.
4. At the end of the storage period and in the absence of another legal basis for their processing, personal data will be deleted or anonymised.

§ 5 RECIPIENTS

1. The data controller does not transfer data in every case and not to all recipients or categories of recipients indicated in the privacy policy - the controller transfers data only when it is necessary for the fulfilment of a given purpose of personal data processing and only to the extent necessary for its fulfilment.
2. In connection with the provision of services, personal data will be disclosed to external entities supporting the administrator's activities, including in particular:
   1. providers responsible for the operation of IT systems [IT support in the operation of an online store, email hosting, maintenance services, server services),
   2. entities such as banks and payment operators - handling electronic payments or payment cards - in the case of a customer who uses the website to make electronic payments or payment card payments, the administrator makes the collected personal data available to the selected entity handling the above payments on the website at the request of the administrator to the extent necessary to handle the payments,
   3. marketing agencies and providers of IT systems used to support marketing (in the scope of marketing services),
   4. providers of accounting, legal and consulting services providing accounting, legal or consulting support to the controller (in particular an accounting office, law firm or debt collection company).
3. The recipients of the data may also be providers of social networking plug-ins, scripts and other similar tools included on the website that enable the browser of a visitor to the website to download content from the providers of the aforementioned plug-ins and to transmit the personal data of the visitor to these providers for this purpose, including: Facebook Ireland Ltd. - the administrator uses Facebook and Instagram social plugins on the online shop website and therefore collects and shares personal data of the customer using the online shop website with Facebook Ireland ltd. (4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland) to the extent and in accordance with the privacy policy available here: https://www.facebook.com/about/privacy/ (this data includes information about activities on the website - including information about the device, websites visited, purchases, advertisements displayed, and how the services are used - regardless of whether the online shop user has a Facebook account and is logged in to Facebook).
4. The recipients of the data may also be public authorities and entities performing public tasks, e.g. in the case of a fraud report, the competent judicial authorities, as well as to the extent and for the purposes arising from legal regulations, e.g. conducting control proceedings at the administrator, the Act on Counteracting Money Laundering.

§ 6 DATA TRANSFER OUTSIDE THE EEA

1. If the controller transfers personal data to a third country. In the event that personal data is transferred outside the European Economic Area, such transfer may only take place under the conditions set out in Article 46, Article 47 or Article 49 of the GDPR. The controller shall transfer personal data outside the EEA only if it is necessary and with an adequate level of protection, primarily through: cooperation with entities processing personal data in countries for which a relevant decision of the European Commission has been issued; application of standard contractual clauses issued by the European Commission; application of binding corporate rules approved by the competent supervisory authority. The controller shall always inform about the intention to transfer personal data outside the EEA at the stage of collecting the data.

§ 7 PROFILING OF PERSONAL DATA

1. Personal data will be processed automatically, including profiling for the purposes of so-called simple profiling (e.g. customising messages and banners to interests) – to better tailor the information and marketing messages about the controller, its products and services, as well as entities related to the controller [link]. We strive to make our promotional, informational and marketing materials valuable to the data subject, therefore, in order to adapt marketing information to the individual preferences and interests of a given customer [presenting advertisements, offers, promotions (discounts)], information about the use of the online shop is used, e.g. by analysing how often you visit the online shop, data about orders, activities in the administrator's sales channels (computer IP, cookies, preferred methods of purchase), data about interest in the administrator's offer/newsletter or assortment, sociodemographic data (e.g. gender, age, location). We strive to ensure that the information obtained through profiling using automated information systems forms the basis for analysing customer expectations and determining the administrator's course of action, without significantly affecting the customer's decisions.

§ 8 VOLUNTARY PROVISION OF PERSONAL DATA

1. Providing personal data on the website is voluntary, but necessary for the realisation of one or more of the purposes of processing personal data indicated in § 4(1) above, which the controller will not be able to realise if the personal data is not provided.

§ 9 RIGHTS OF THE DATA SUBJECT RELATED TO THE PROTECTION OF PERSONAL DATA

1. In the case of asserting your rights, please direct your correspondence to the data provided in § 2 of the policy. At the same time, please send all necessary information that will allow us to clearly identify the entity exercising the rights.
2. Every entity whose data is processed by the administrator has the right to:
   1. access the content of personal data, including requesting a copy, 10
   2. request rectification,
   3. delete personal data (the right to be forgotten),
   4. limit the processing of personal data,
   5. the right to transfer personal data to another administrator if the processing is based on a contract [Article 6(1)(b) of the GDPR] or on consent [Article 6(1)(a) of the GDPR],
   6. the right to object to the processing of personal data, in particular to direct marketing based on Article 6(1)(f) GDPR. The right to object to the processing of personal data for purposes based on Article 6(1)(f) GDPR for reasons relating to a particular situation,
   7. the right to lodge a complaint with the President of the Personal Data Protection Office.
   8. the right to withdraw consent, which can be done at any time. The withdrawal of consent shall not affect the processing of data carried out prior to such withdrawal. Consent may be revoked by them at any time, without affecting the lawfulness of the processing,
3. If you believe that the processing of your personal data violates applicable law, you have the right to lodge a complaint with a supervisory authority. To do so, you can contact the data protection authority responsible for your place of residence. You can also contact the data protection authority responsible for our company. You can find the contact details below: Data Protection Office, ul. Stawki 2 00-193 Warsaw, [email protected].

§ 10 COOKIES AND SIMILAR TECHNOLOGY

1. The administrator uses cookies (or functionalities similar to cookies) to collect information about every person visiting the online shop. The website uses cookies, and detailed information in this regard is presented below. Obtaining and storing information using cookies is possible based on the user's consent. By default, web browsers or other software installed on a computer or other device connected to the network allow cookies to be placed on that device.
2. Cookies are small text files that are installed on the device of a user browsing a website. Cookies collect information that facilitates the use of a website – e.g. by remembering the user's visits to the website and the activities performed by them. The cookies used by the administrator are safe for the user's device. In particular, it is not possible for viruses or other unwanted or malicious software to enter users' devices in this way. These files allow the software used by the user to be identified and the website to be customised for each user. Cookies usually contain the name of the domain from which they originate, their storage time on the device and an assigned value.
3. The administrator uses the so-called service cookies primarily to provide the user with electronically supplied services and to improve the quality of these services. Therefore, the administrator and other entities providing analytical and statistical services on his behalf use cookies, storing information or accessing information already stored in the user's telecommunications terminal equipment (computer, telephone, tablet, etc.). The cookies used for this purpose include:
   1. Cookies with user input (session ID) for the duration of a session;
   2. Session cookies of multimedia players (e.g. flash cookies) for the duration of a session;
   3. persistent cookies used to personalise the user interface for the duration of the session or a little longer.
4. The user has the option to restrict or disable cookie access to their device. If this option is used, it will be possible to use the website, except for functions that by their nature require cookies.
5. Cookies are stored for non-essential purposes, including marketing, on the basis of your consent (Article 6(1)(a) GDPR). These cookies are therefore only activated if you consent to storage by accepting the cookie banner on the website.

The setting selected during the first visit in response to the cookie notification (pop-up) will be saved. The selected settings can be adjusted at any time in the privacy settings.

6. The administrator uses administrator cookies for the following purposes:
   1. website configuration and implementation of processes necessary for the full functionality of the online store - recognising the device and displaying the website accordingly, tailored to its individual needs; remembering the data needed to use the online store,
   2. analyses and research as well as audience measurement - creating anonymous statistics that help to understand how users of the online shop use it, which enables the improvement of the structure and content, functionality of the online shop,
   3. to ensure the security of the online shop.

The basis for the processing of the data obtained in this way is the legitimate interest of the controller, which is the need to ensure the highest quality of the content presented by the controller by adapting it to the preferences of the users and marketing - including direct marketing - of the products and services of the controller or its partners, in which case the partners do not participate in the processing of customer data. Insofar as the administrator's partners providing tools to support the functioning of the online store may also have direct access to this information, the legal basis for such processing is the customer's voluntary consent.

7. The user can independently and at any time change the settings for cookies, specifying the conditions for their storage and access by cookies to the user's device. The user can make changes to the settings referred to in the previous sentence using the web browser settings or by configuring the service. These settings can be changed in particular in such a way as to block the automatic handling of cookies in the web browser settings or to inform the user each time cookies are placed on the user's device. Detailed information about the possibilities and ways of handling cookies is available in the software (web browser) settings. The user can also object to the activities of the administrator undertaken for the purpose described above. If consent is given, including for the presentation, creation, allocation and implementation of dedicated advertisements, offers or promotions (discounts) tailored to the user's preferences, it may be withdrawn at any time; however, this will not affect the lawfulness of processing based on consent before its withdrawal.
8. The user can delete cookies at any time using the functions available in the web browser they use.
9. Restricting the use of cookies may affect some of the functionalities available on the website.
10. Each user of the websites should take care of the security of their devices used to access the Internet. Such a device should have an anti-virus programme with an up-to-date virus definition database, an up-to-date and secure version of a web browser and a firewall enabled. Furthermore, the user should regularly check whether the operating system and the programs installed on it have the latest updates, because attacks are carried out using errors detected in the installed software. Software manufacturers try to eliminate such threats with updates.
11. The use of cookies to collect data for marketing purposes or for purposes other than those necessary to display the website, including accessing data stored on the user's device, requires the user's consent. This consent can be withdrawn at any time. Cookies that are required to provide the telecommunications service (data transmission to display content) are exempt from this requirement. You can delete or block cookies and withdraw your consent to the use of cookies in your browser settings. You can find more detailed information on this subject via the following links:

• Google Chrome: http://support.google.com/chrome/bin/answer.py?hl=pl&answer=95647
• Mozilla Firefox: http://support.mozilla.org/pl/kb/ciasteczka
• Internet Explorer: https://support.microsoft.com/pl-en/help/17442/windows-internetexplorer-delete-manage-cookies
• Opera: http://help.opera.com/windows/12.10/pl/cookies.html
• Safari: https://support.apple.com/kb/ph5042?locale=en-gb

12. Cookie data will be stored until the consent is withdrawn or an objection is raised. The controller may erase personal data if it is not used for marketing purposes for a period of 3 years, unless the controller is required by law to process the personal data for a longer period.
13. The controller uses various solutions and tools for analytical and marketing purposes.

We only work with processors who are able to ensure an adequate level of protection for your personal data. We disclose your personal data to third parties or public authorities when we are legally obliged to do so. We may disclose your personal data to third parties if you have given your consent or if there are other legal grounds for doing so.

FACEBOOK ADS

Facebook Ads is an advertising system within Facebook and is provided by Facebook, Inc., 1602 s. California ave. Palo Alto, CA 94304, USA., which we use to display ads to Facebook users where the service uses so-called remarketing codes. The codes are used to display personalised ads to individual customers within the advertising network of the respective provider (Google, Facebook). These networks include websites of the providers as well as their partners. For more information, please visit the websites of the providers, including:

• Google:https://policies.google.com/technologies/types?hl=pl
• Facebook:https://www.facebook.com/policy/cookies/

We use it to conduct remarketing and advertising campaigns on the Facebook advertising network, to create campaign performance reports and to track conversions. Facebook Ads collects behavioural data about users based on cookies and stores the data in its data centres, including in Lulea, Sweden, in the European Union. The information collected by Facebook Pixel is anonymous – it does not allow us to identify you. We can only see what actions you have taken on our site. However, we would like to inform you that Facebook may combine the collected information with other information about you collected through your use of the Facebook website and use it for its own purposes, including marketing. You can also manage your privacy settings from your Facebook account. Here you will find useful information in this regard: https://www.facebook.com/ads/settings.

You can find more information directly there: https://www.facebook.com/privacy/explanation

GOOGLE ANALYTICS

This is provided by Google LLC, 1600 Ampitheatre Parkway, Mountain View, CA 94043, USA.

Google Analytics cookies are files used by Google to analyse how users use the online store, to create statistics and reports on the functioning of the website. Google does not use the collected data to identify the user or combine this information to identify the user. Detailed information on the scope and rules of data collection in connection with this service can be found at the following link: https://www.google.com/intl/pl/policies/privacy/partners.

You can prevent the data collected by cookies on our and other websites that use GA from being recorded by installing a corresponding browser plug-in: https://tools.google.com/dlpage/gaoptout

However, the data processing within GA is described in detail by Google: https://support.google.com/analytics/answer/6004245.

GOOGLE TAG MANAGER

We use Google Tag Manager from Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA). This tool allows us to manage scripts on the online shop website, e.g. conversion tracking scripts from advertising systems such as Google Ads, scripts related to user consents, tracking user behaviour through analytical tools such as Google Analytics. The Google Tag Manager tool is used to manage website tags via an interface. The use of Google Tag Manager does not involve the storage of cookies or the collection of personal data. The tool enables other tags that may collect data under certain circumstances. Google Tag Manager does not access this data. If the storage option is deactivated at domain or cookie level, this setting will apply to all tracking tags implemented via Google Tag Manager.

However, the data obtained in this way is generalised - aggregated data on the activation of these scripts, without the possibility of identifying a specific user. Detailed information on the scope and rules of data collection in connection with this service can be found at the following link: https://policies.google.com/technologies/ads?hl=pl

VIRTUAL POLAND

On our websites, third parties place and access information in the form of cookies and other similar technologies on your end device (e.g. computer, smartphone). These are our trusted partners with whom we constantly cooperate to customise the advertising on our and their websites to your needs and interests, as well as the services provided by us and our trusted partners. Such trusted partners include entities from the Wirtualna Polska capital group. Detailed information on how Wirtualna Polska processes your data can be found in the privacy policy of Wirtualna Polska.

GOOGLE ADS

The Google Adwords remarketing service is offered by Google LLC (www.google.com).

We use Google AdWords to promote our website in search results and on third-party websites. When you visit our website, a Google remarketing cookie is automatically stored on your device. This cookie enables interest-based advertising by using a pseudonymous user ID and based on the pages you visit.

Further processing of data only takes place if you have agreed with Google that your browsing history and use of the application may be linked to your account and information from your Google account may be used to personalise advertisements that are displayed on websites. If you are logged in to Google while visiting our website, Google will use your data in connection with Google Analytics data to create and define target group lists for cross-device remarketing. To this end, Google temporarily links your personal data with Google Analytics data to create target groups.

This tool measures the effectiveness of advertising campaigns carried out by the administrator, allowing for the analysis of data such as keywords or the number of unique users. Information on data processing by Google in the scope of the above service is available at the following link: https://policies.google.com/technologies/ads?hl=pl

OTHER SOCIAL MEDIA PLUGINS

Our website uses social plugins and other social media tools provided by services such as Facebook, Instagram and Pinterest.

When you visit our website, which contains such a plugin, your browser establishes a direct connection to the servers of the social media service providers. The content of the plugin is transmitted directly to your browser by the respective provider and integrated into the page. Through this integration, the providers receive the information that your browser has accessed the respective page, even if you do not have a profile with the respective provider or are not currently logged in. This information, including your IP address, is sent directly to a server of the respective provider (some servers are located in the USA) and stored there.

If you are logged in to one of the social networks, the respective provider can directly assign the visit to our website to your profile in the social network.

If you use the respective plugin to share content, the corresponding information will also be sent directly to the server of the respective service provider and stored there. Furthermore, this information will be published on the respective social media platform and will be visible to people you have added as contacts. The purpose and scope of the data collection and the further processing and use by the service providers, as well as the possibility of contacting and your rights in this regard and the possibility of making settings to protect your privacy are described in the privacy policy of individual service providers.

• Facebook –https://www.facebook.com/legal/fb_work_privacy
• Pinterest –https://policy.pinterest.com/pl/privacy-policy

If you do not want social networks to assign the data collected during your visit to our website directly to your profile in the respective service, you must log out of the service before visiting our website. You can also use script-blocking browser extensions to prevent these plug-ins from loading.

§ 11 CHANGES TO THE PRIVACY POLICY

1. The policy is reviewed on an ongoing basis and updated as necessary. In the event of a policy update, the user will be notified by displaying information or by sending an email to the user. In some cases, the user may be notified in advance of a policy update, and the fact of using the online shop services will mean acceptance of the updated version of the policy.
2. Users who do not accept the terms and conditions of the online shop after a new version of the policy has come into effect may no longer use the online shop.
3. Last updated on 01.04.2023

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