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Privacy Policy

Privacy Policy

This Privacy Policy defines the rules for storing and accessing data on Users’ Devices using the Service for the purpose of providing electronic services by the Administrator and the rules for collecting and processing personal data of Users provided by them personally and voluntarily through tools available on the Service.

This Privacy Policy is an integral part of the Service Regulations, which define the rules, rights, and obligations of Users using the Service.

§1 Definitions

  • Service – “Luvi.pl” online service operating at https://luvi.pl/

  • External Service – internet services of partners, service providers, or service recipients cooperating with the Administrator

  • Service Administrator / Data Administrator – The Service Administrator and Data Administrator (hereinafter Administrator) is the company “Luvi Sp. z o.o.,” conducting business at ul. Przemysłowa 24, 21-100 Lubartów, with the assigned tax identification number (NIP): 714-18-11-684, providing electronic services through the Service

  • User – a natural person for whom the Administrator provides electronic services through the Service.

  • Device – an electronic device with software through which the User accesses the Service

  • Cookies – text data collected in the form of files placed on the User’s Device

  • GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals concerning the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)

  • Personal Data – means information about an identified or identifiable natural person (“data subject”); an identifiable person is one who can be directly or indirectly identified, in particular by reference to an identifier such as a name and surname, identification number, location data, internet identifier, or one or more specific factors determining the physical, physiological, genetic, mental, economic, cultural, or social identity of a natural person

  • Processing – means an operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation, or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment, or combination, restriction, erasure, or destruction

  • Restriction of processing – means the marking of stored personal data with the aim of limiting their processing in the future

  • Profiling – means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements

  • Consent – consent of the data subject means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data concerning him or her

  • Personal data breach – means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed

  • Pseudonymization – means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person

  • Anonymization – Anonymization of data is an irreversible process of operations on data that destroys/overwrites “personal data,” making identification or linking of a specific record to a particular user or natural person impossible.

§2 Data Protection Officer

Based on Article 37 of the GDPR, the Administrator has not appointed a Data Protection Officer.

For matters concerning the processing of data, including personal data, please contact the Administrator directly.

§3 Types of Cookies

  • Internal Cookies – files placed and read from the User’s Device by the teleinformation system of the Service

  • External Cookies – files placed and read from the User’s Device by the teleinformation systems of External Services. Scripts of External Services that may place Cookie files on the User’s Device have been consciously placed in the Service through scripts and services provided and installed in the Service

  • Session Cookies – files placed and read from the User’s Device by the Service during one session of the Device. After the session ends, the files are removed from the User’s Device.

  • Persistent Cookies – files placed and read from the User’s Device by the Service until they are manually deleted. The files are not automatically deleted after the Device’s session unless the User’s Device is configured to delete Cookie files after the Device’s session.

§4 Data Storage Security

  • Mechanisms for storing and reading Cookie files – Mechanisms for storing, reading, and exchanging data between Cookie files saved on the User’s Device and the Service are carried out through built-in mechanisms of web browsers and do not allow for the retrieval of other data from the User’s Device or data from other websites visited by the User, including personal data or confidential information. It is also practically impossible to transfer viruses, trojans, and other worms to the User’s Device.

  • Internal Cookies – The Cookie files used by the Administrator are safe for Users’ Devices and do not contain scripts, content, or information that could threaten the security of personal data or the security of the User’s Device.

  • External Cookies – The Administrator makes every possible effort to verify and select service partners regarding the security of Users. The Administrator selects well-known, large partners with global social trust for cooperation. However, the Administrator does not have complete control over the content of Cookie files from external partners. For the security of Cookie files, their content, and the licensed use by scripts installed in the service, originating from external services, the Administrator is not responsible to the extent permitted by law. The list of partners is provided in the further part of the Privacy Policy.

  • Cookie Control

  • Threats on the User’s Side – The Administrator applies all possible technical measures to ensure the security of data placed in Cookie files. However, it should be noted that ensuring the security of this data depends on both sides, including the User’s activity. The Administrator is not responsible for intercepting this data, impersonating the User’s session, or deleting it, as a result of the intentional or unintentional activity of the User, viruses, trojans, and other spyware that may or may have been infected on the User’s Device. To protect against these threats, Users should adhere to internet usage principles.

  • Storage of Personal Data – The Administrator ensures that every effort is made to process voluntarily provided personal data by Users securely, with limited access, and in accordance with their intended use and processing purposes. The Administrator also ensures that every effort is made to secure the data held against loss, through the use of appropriate physical and organizational security measures.

§5 Purposes for which Cookie files are used

  • Improving and facilitating access to the Service
  • Personalizing the Service for Users
  • Enabling login to the service
  • Marketing, Remarketing on external services
  • Ad serving services
  • Affiliate services
  • Conducting statistics (users, number of visits, types of devices, link, etc.)
  • Serving multimedia services
  • Providing social services

§6 Purposes of Personal Data Processing

Personal data voluntarily provided by Users is processed for one of the following purposes:

  • Execution of electronic services:
    • Registration and maintenance of User accounts in the Service and related functionalities
    • Newsletter services (including sending promotional content with consent)
    • Commenting/liking posts in the Service without the need for registration
    • Sharing information about content in the Service on social media or other websites.
  • Communication from the Administrator to Users regarding Service matters and data protection
  • Ensuring the legally justified interests of the Administrator

Anonymously and automatically collected user data is processed for one of the following purposes:

  • Statistical analysis
  • Remarketing
  • Displaying ads tailored to User preferences
  • Affiliate program management
  • Ensuring the legally justified interests of the Administrator

§7 Cookies of External Services

The Administrator uses javascript scripts and web components of partners in the Service, who may place their own cookies on the User’s device. Remember that you can decide on allowed cookies in your browser settings for individual websites. Below is a list of partners or their services implemented in the Service that may place cookies:

Services provided by third parties are beyond the control of the Administrator. These entities may change their service terms, privacy policies, data processing purposes, and cookie usage methods at any time.

§8 Types of Collected Data

The Service collects data about Users. Some data is collected automatically and anonymously, while some are personal data voluntarily provided by Users during the registration for specific services offered by the Service.

Automatically collected anonymous data:

  • IP address
  • Browser type
  • Screen resolution
  • Approximate location
  • Visited pages of the service
  • Time spent on a specific page of the service
  • Operating system type
  • Previous page address
  • Referring page address
  • Browser language
  • Internet connection speed
  • Internet service provider

Data collected during registration:

  • Email address

Data collected during Newsletter subscription:

  • Name/nickname
  • Email address
  • IP address (collected automatically)

Data collected when adding a comment:

  • Name and surname/nickname
  • Email address
  • Website address
  • IP address (collected automatically)

Some data (without identifying information) may be stored in cookies. Some data (without identifying information) may be transmitted to a statistical services provider.

§9 Access to Personal Data by Third Parties

As a rule, the sole recipient of personal data provided by Users is the Administrator. Data collected as part of the provided services is not transferred or sold to third parties.

Entities responsible for maintaining the infrastructure and services necessary for running the service may have access to data (usually based on a Data Processing Agreement), including:

  • Hosting companies providing hosting or related services for the Administrator
  • Companies through which the Newsletter service is provided

Data Processing Agreement – Hosting, VPS, or Dedicated Server Services

The Administrator uses the services of an external hosting provider, VPS, or Dedicated Servers – Cyber Folks SA. All data collected and processed on the site is stored and processed in the provider’s infrastructure located in Poland. There is a possibility of accessing data due to service-related work carried out by the provider’s staff. Access to this data is governed by the agreement between the Administrator and the Service Provider.

§10 Method of Processing Personal Data

Personal data voluntarily provided by Users:

  • Personal data will not be transferred outside the European Union unless it has been published due to individual user action (e.g., commenting or posting), making the data accessible to anyone visiting the service.
  • Personal data will not be used for automated decision-making (profiling).
  • Personal data will not be sold to third parties.

Anonymized data (without personal data) collected automatically:

  • Anonymized data (without personal data) may be transferred outside the European Union.
  • Anonymized data (without personal data) will not be used for automated decision-making (profiling).
  • Anonymized data (without personal data) will not be sold to third parties.

§11 Legal Basis for Processing Personal Data

The Service collects and processes user data based on:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons concerning the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation):
    • Art. 6(1)(a) – the data subject has given consent to the processing of their personal data for one or more specific purposes
    • Art. 6(1)(b) – 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
    • Art. 6(1)(f) – processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party
  • Act of May 10, 2018, on the protection of personal data (Journal of Laws of 2018, item 1000)
  • Act of July 16, 2004, Telecommunications Law (Journal of Laws of 2004, No. 171, item 1800)
  • Act of February 4, 1994, on copyright and related rights (Journal of Laws of 1994, No. 24, item 83)

§12 Duration of Personal Data Processing

Personal data voluntarily provided by Users:

In principle, the provided personal data is stored only for the duration of the Service provision within the Service by the Administrator. They are deleted or anonymized within 30 days from the end of the service provision (e.g., deletion of a registered user account, unsubscription from the Newsletter, etc.)

An exception is a situation that requires securing the legally justified purposes of further data processing by the Administrator. In such a situation, the Administrator will store the specified data, from the time of the User’s request for their deletion, for no longer than 3 years in the case of a violation or suspicion of a violation of the service regulations by the User.

Anonymized data (without personal data) collected automatically:

Anonymized statistical data, not constituting personal data, is stored by the Administrator for an indefinite period for the purpose of service statistics.

§13 User Rights Related to Personal Data Processing

The Service collects and processes user data based on:

  • Right of access to personal data
    Users have the right to access their personal data, exercised upon request submitted to the Administrator

  • Right to rectification of personal data
    Users have the right to request the Administrator to promptly correct inaccurate or incomplete personal data, exercised upon request submitted to the Administrator

  • Right to erasure of personal data
    Users have the right to request the Administrator to promptly erase personal data, exercised upon request submitted to the Administrator. In the case of user accounts, data deletion involves anonymizing data allowing user identification. The Administrator reserves the right to suspend the execution of the data deletion request to protect the legally justified interests of the Administrator (e.g., in case of a user’s violation of the Terms of Service or if the data was obtained through correspondence).
    For the Newsletter service, users can independently delete their personal data using the link provided in each email message.

  • Right to restriction of processing personal data
    Users have the right to restrict the processing of personal data in cases specified in Article 18 of the GDPR, including challenging the accuracy of personal data, exercised upon request submitted to the Administrator

  • Right to data portability
    Users have the right to receive their personal data from the Administrator in a structured, commonly used, machine-readable format, exercised upon request submitted to the Administrator

  • Right to object to processing of personal data
    Users have the right to object to the processing of their personal data in cases specified in Article 21 of the GDPR, exercised upon request submitted to the Administrator

  • Right to lodge a complaint
    Users have the right to lodge a complaint with the supervisory authority responsible for data protection.

§14 Contact with the Administrator

The Administrator can be contacted in one of the following ways:

  • Mailing address – Luvi Sp. z o.o., ul. Przemysłowa 24, 21-100 Lubartów

  • Email address – t.krzyzanowski@luvi.pl

  • Phone call – +48 81 855 44 38

  • Contact form – available at /contact

§15 Service Requirements

  • Limiting the storage and access to Cookie files on the User’s device may cause some functions of the Service to malfunction.

  • The Administrator is not responsible for the improper functioning of Service functions if the User restricts in any way the ability to store and read Cookie files.

§16 External Links

In the

Service – articles, posts, entries, or user comments may contain links to external websites with which the Service Owner does not cooperate. These links and the pages or files indicated under them may be dangerous for your Device or pose a threat to the security of your data. The Administrator is not responsible for the content outside the Service.

§17 Changes in the Privacy Policy

  • The Administrator reserves the right to change this Privacy Policy without informing Users in the scope of the use and application of anonymous data or the use of Cookie files.

  • The Administrator reserves the right to change this Privacy Policy regarding the processing of Personal Data, informing Users with user accounts or subscribed to the newsletter service via email within 7 days of the change. Further use of the services means familiarity with and acceptance of the introduced changes to the Privacy Policy. If the User disagrees with the changes made, they are obliged to delete their account from the Service or unsubscribe from the Newsletter service.

  • The introduced changes in the Privacy Policy will be published on this subpage of the Service.

  • The introduced changes come into effect upon their publication.