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This Privacy Policy defines the rules for processing personal data obtained via the online store turwear.eu (hereinafter: the “Online Store”).
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The owner of the Online Store and the data controller is Serhii Shyrokostup “TURWEAR”, with its registered office at ul. Pory 57/74, 02-757 Warsaw, Poland, NIP: 5214124328, REGON: 542178296, hereinafter “TURWEAR”.
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Personal data collected by Turwear via the Online Store is processed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation, “GDPR”), and repealing Directive 95/46/EC.
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Turwear takes special care to respect the privacy of Customers visiting the Online Store.
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| § 1 Type of data processed, purposes and legal basis |
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Turwear collects information about natural persons concluding legal transactions unrelated to their business activity, persons conducting business or professional activity on their own behalf, and natural persons representing legal entities or organizational units without legal personality, conducting business or professional activity on their own behalf (collectively, “Customers”).
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Customers’ personal data is collected in the following cases:
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a) |
when registering an account in the Online Store, for the purpose of creating and managing an individual account. Legal basis: necessity for performance of the Account service contract (Art. 6(1)(b) GDPR);
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b) |
when placing an order in the Online Store, for the purpose of performance of the sales contract. Legal basis: necessity for performance of the sales contract (Art. 6(1)(b) GDPR);
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c) |
when subscribing to the newsletter, for the purpose of performing an electronic communication service contract. Legal basis: consent of the data subject for performance of the Newsletter service (Art. 6(1)(a) GDPR).
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When registering an account, the Customer provides:
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a) |
email address.
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During registration, the Customer sets a personal account password. The Customer may change the password later as described in § 5.
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When placing an order, the Customer provides the following data:
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a) |
email address;
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b) |
address data:
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a. |
postal code and city;
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b. |
country;
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c. |
street with building/apartment number.
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c) |
first and last name;
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d) |
telephone number.
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6. |
For Entrepreneurs, the above data is additionally extended to:
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a) |
company name;
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b) |
NIP number.
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7. |
When subscribing to the Newsletter, the Customer provides only their email address.
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8. |
While using the Store’s website, additional information may be collected, in particular: the IP address assigned to the Customer’s device or the external IP of their ISP, domain name, browser type, access time, operating system.
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9. |
Navigation data may also be collected, including information about links clicked or other actions taken in our Online Store. Legal basis: legitimate interest (Art. 6(1)(f) GDPR), consisting of facilitating use of electronic services and improving their functionality.
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For the establishment, pursuit and enforcement of claims, certain personal data provided by the Customer may be processed, such as: name, surname, service usage data if claims arise from the Customer’s use of services, and other data necessary to prove the existence and extent of a claim. Legal basis: legitimate interest (Art. 6(1)(f) GDPR), consisting of establishing, pursuing and enforcing claims and defending against claims in judicial or administrative proceedings.
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11. |
Providing personal data to Turwear is voluntary in relation to sales or service contracts via the Store’s website; however, failure to provide required data during registration prevents Account creation, and failure to provide required data when ordering without registration prevents order submission and fulfillment.
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| § 2 Data recipients and retention periods |
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Customer personal data is transferred to service providers used by Turwear to operate the Online Store. Depending on contractual terms, these providers either process data on Turwear’s instructions (processors) or determine their own purposes and methods (controllers).
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Processors: Turwear uses providers who process personal data exclusively on Turwear’s instructions, including hosting providers, accounting services, marketing platforms, website traffic analytics, and campaign effectiveness tools;
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b) |
Controllers: Turwear uses providers who independently determine their purposes and methods of processing Customers’ personal data, such as electronic payment and banking service providers. Turwear also informs Users that it entrusts personal data processing to:
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Edrone Sp. z o.o., ul. Lekarska 1, 31-203 Kraków, NIP: 676-248-20-64, KRS: 0000537197 – for use of the edrone.me system to send the newsletter and for marketing purposes solely for email, SMS and social media campaigns initiated or specified by the Controller.
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Tracking technologies used on the Store website:
– edrone tracking codes for website analytics and marketing campaigns solely for email, SMS and social media campaigns initiated or specified by the Controller via edrone.
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Location: Service providers are based primarily in Poland and other countries of the European Economic Area (EEA).
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Customers’ personal data is stored as follows:
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a) |
If processing is based on consent, personal data is processed until consent is withdrawn and thereafter for the statute of limitations period applicable to claims by or against Turwear. Unless otherwise specified, the limitation period is six years (three years for periodic performance or business-related claims).
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b) |
If processing is based on contract performance, personal data is processed as long as necessary to fulfill the contract and thereafter for the statute of limitations period. Unless otherwise specified, the limitation period is six years (three years for periodic performance or business-related claims).
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When a purchase is made in the Store, personal data may be transferred to Poczta Polska S.A. (Polish Post) in Warsaw for the purpose of delivering the ordered goods.
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Navigation data may be used to provide better service, statistical analysis, adaptation of the Online Store to Customer preferences, and Store administration.
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If the Customer subscribes to the newsletter, Turwear will send commercial electronic messages about promotions and new products available in the Online Store.
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Upon request, Turwear provides personal data to authorized state bodies, in particular the Prosecutor’s Office, Police, President of the Data Protection Office, President of the Competition and Consumer Protection Office, or President of the Office of Electronic Communications.
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| § 3 Cookies mechanism, IP address |
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The Online Store uses small files called cookies. They are stored by Turwear on the visitor’s device if the browser allows. A cookie typically contains the domain name, its expiration date, and a randomly generated identifier. Data collected via cookies helps tailor Turwear’s products to individual preferences and needs, and enables generation of general statistics on product visits.
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Turwear uses two types of cookies:
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Session cookies: removed when the browser session ends or the device is turned off. Session cookies do not retrieve personal or confidential information from the Customer’s device.
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Persistent cookies: stored on the device until they are deleted or expire. Persistent cookies do not retrieve personal or confidential information from the Customer’s device.
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Turwear uses its own cookies for:
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authenticating the Customer and maintaining their session so they do not need to re-enter their login and password on each page;
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analytics, research and auditing of viewership to create anonymous statistics that help understand how Customers use the Store’s website and improve its structure and content.
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The cookies mechanism is safe for Customers’ computers. It cannot introduce viruses or malware. Customers can restrict or disable cookies in their browsers; in that case, the Store will operate except for features that inherently require cookies.
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Below are instructions for changing cookie settings in popular browsers:
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a) |
Browser: Internet Explorer;
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b) |
Browser: Microsoft EDGE;
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c) |
Browser: Mozilla Firefox;
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d) |
Browser: Chrome;
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e) |
Browser: Safari;
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f) |
Browser: Opera.
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7. |
Turwear may collect Customers’ IP addresses. An IP address is assigned dynamically by the ISP and used for diagnosing server issues, statistical analyses (e.g. identifying regions with the most visits), administering and improving the Online Store, and for security and identifying unwanted automated browsing programs.
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8. |
The Online Store contains links to other websites. Turwear is not responsible for privacy practices on those sites.
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| § 4 Rights of data subjects |
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Right to withdraw consent – legal basis: Art. 7(3) GDPR.
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The Customer has the right to withdraw any consent given to Turwear.
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Withdrawal is effective upon receipt of the withdrawal.
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Withdrawal does not affect lawfulness of processing before withdrawal.
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Withdrawal has no negative consequences for the Customer but may preclude further use of services requiring consent.
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Right to object to processing – legal basis: Art. 21 GDPR.
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The Customer may object at any time, for reasons relating to their particular situation, to processing of their data based on legitimate interest (e.g., marketing, usage statistics, site functionality improvements, satisfaction surveys).
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b) |
Unsubscribing by email from marketing communications constitutes an objection to processing, including profiling, for those purposes.
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c) |
If the objection is upheld and no other legal basis exists, the Customer’s data will be deleted.
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Right to erasure (“right to be forgotten”) – legal basis: Art. 17 GDPR.
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The Customer may request deletion of all or some personal data.
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b) |
The Customer may request deletion if:
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data is no longer necessary for the purposes collected or processed;
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the consent on which processing was based is withdrawn;
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the Customer objected to marketing processing;
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data is processed unlawfully;
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data must be erased to comply with a legal obligation under EU or Member State law;
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data was collected in relation to information society services.
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g) |
Despite a deletion request, Turwear may retain certain data necessary to establish, pursue or defend claims, and to comply with legal obligations under EU or Member State law. This includes name and email (retained for complaints and claims), and if applicable, residential/correspondence address and order number (retained for handling complaints and claims related to sales or services).
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Right to restrict processing – legal basis: Art. 18 GDPR.
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The Customer may request restriction of processing. While the request is pending, processing of the data in question is suspended and no communications, including marketing, will be sent.
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The Customer may request restriction if:
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the accuracy of data is contested (restriction up to 7 days for verification);
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processing is unlawful and erasure is objected to (restriction instead of erasure);
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data is no longer needed for original purposes but is required by the Customer for legal claims;
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the Customer objected to processing – restriction remains until it is determined whether the Customer’s rights override Turwear’s legitimate interests.
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Right of access – legal basis: Art. 15 GDPR.
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The Customer has the right to obtain from the Controller confirmation of whether personal data are processed and, if so, the right to:
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access their personal data;
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obtain information about processing purposes, categories of data, recipients or categories of recipients, planned storage period or criteria, rights under GDPR including the right to lodge a complaint, data sources, automated decision-making/profiling, and safeguards for transfers outside the EU;
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receive a copy of their personal data.
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Right to rectification – legal basis: Art. 16 GDPR.
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The Customer has the right to request immediate correction of inaccurate personal data and completion of incomplete data, including by providing an additional statement, by emailing a request in accordance with § 6 of this Privacy Policy.
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Right to data portability – legal basis: Art. 20 GDPR.
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The Customer has the right to receive their personal data provided to the Controller in a commonly used machine-readable format (CSV) and to transmit it to another data controller, and may request direct transfer if technically feasible.
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Turwear will comply with or refuse requests under these rights without undue delay, no later than one month of receipt. If necessary due to complexity or number of requests, the period may be extended by two months, with prior notice within one month of receipt stating the reasons and extension period.
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The Customer may lodge complaints, inquiries, or requests concerning processing of their personal data and exercise of their rights.
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The Customer may request from Turwear a copy of standard contractual clauses by contacting as specified in § 6 of this Privacy Policy.
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The Customer has the right to lodge a complaint with the President of the Personal Data Protection Office for violations of their data protection rights or other GDPR rights.
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| § 5 Security management – password |
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Turwear provides a secure, encrypted connection (SSL) for transmission of personal data and account login, using a certificate from a leading global security provider.
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If a Customer loses their password, the Store allows generation of a new password; Turwear does not send password reminders. Passwords are stored encrypted. To generate a new password, enter your email in the “Forgot password” form; you will receive an email with a link to set a new password.
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Turwear never sends any correspondence requesting login credentials or passwords.
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| § 6 Changes to the Privacy Policy |
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The Privacy Policy may be amended; Turwear will inform Customers at least 7 days in advance.
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Questions regarding the Privacy Policy should be directed to: turwear.sales@gmail.com
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Last updated: 05.08.2025
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