Privacy Policy of the Online Store
Swing Lab

We have created this privacy policy for people visiting the website https://www.swinglab.pl (hereinafter the “Website”), i.e. the Swing Lab online store (hereinafter the “Store”).

The controller of your personal data in connection with using the Store is: Damian Kajfasz, an entrepreneur conducting business activity under the business name Firma Handlowa Damian Kajfasz with its registered office at: ul. Ks. Gołby 71, 34-116 Bachowice, entered in the Central Register and Information on Economic Activity (CEIDG), NIP: 5512614587, REGON: 122457914.

In all matters related to the processing of personal data, you can contact us at the following e-mail address: kontakt@swinglab.pl. You may also contact us in writing at the registered office address provided above.

For convenience, we have divided this document into two parts:

1. Cookies and other technologies
2. Other purposes of processing personal data of Store users

If you are short on time, click the link for the part that interests you the most. If you have a bit more time, we encourage you to read the entire text.

I. COOKIES AND OTHER TECHNOLOGIES

We use cookies and other similar mechanisms to understand how users use our Website and for marketing purposes, including to display ads to them elsewhere on the Internet.

# What are cookies?

A cookie is a small text file saved by a website on your computer, phone, or other device you use to browse the website. A cookie contains data about your use of that website.

Some cookies are necessary for our Store to function and cannot be disabled.
In other cases, when you first visit our Website, we ask you to consent to the installation of cookies. We do not use advertising or analytics cookies (or any cookies other than necessary ones) without your consent.

# What cookies do we use?

1. Necessary cookies
   • These cookies are used for the proper functioning of the website. You cannot disable them, because if you do, our website simply will not work properly.
   • In this scope, we use a tool that stores your privacy settings. It shows your consent or lack of consent for running specific types of cookies on our website.
   • Other necessary cookies on our Website are used for its correct operation and management, including making changes to the website and enabling tracking tools that you consent to.
2. Statistical analysis of our Website
   • We use analytics tools that collect analytical data, thanks to which we can understand how users use our Website. The data we receive from these tools does not give us information about a specific person identified by name, but it allows us to record various aspects of how a given user uses the Website. We can aggregate and analyze this data statistically and then use it to make decisions about changes to our Store and/or the ways we run our advertising and marketing communications.
   • A list of the analytics tools used on our Website along with an explanation of: (i) who the provider is, (ii) what the tool is used for, (iii) what data is collected under the tool – can be found in Appendix No. 1 to this policy, and in short also in the cookie consent management panel.
3. Advertising cookies
   • We use advertising tools that allow us to display our ads on other websites you visit, including social media (so-called targeted ads), measure the effectiveness of our advertising campaigns, and tailor the content of our messages addressed to you based on the information we have about you.
   • In the Store, we enable subscription to our newsletter. In connection with this, cookies are used to embed the subscription form on our Website and to measure the effectiveness of sign-ups via this form. Modern e-mail marketing systems allow us to combine analytics data from mailing campaigns with analytics data from the Store. We may use this data to optimize the content of messages sent to newsletter subscribers.
   • A list of the advertising tools used on our Website along with an explanation of: (i) who the provider is, (ii) what the tool is used for – can be found in Appendix No. 1 to this policy, and in short also in the cookie consent management panel.
4. Functional cookies
   • Some cookies on our website are used to enable additional tools on the Store’s website, such as a chat, a product review and/or rating module, the ability to recommend a product to a friend, the ability to display recently viewed products in our Store, etc.
   • A list of functional tools used on our Website along with an explanation of what they are used for can be found in the cookie consent management panel.
5. Social media plug-ins and links
   • On our Website, we have placed links to our social media profiles: Facebook / Instagram / TikTok. If you visit our profile on a given platform, the owner of that platform will receive – as in the case of users moving from any other website to another website – information that you reached that platform from our Store.
   • Details about data processing by these social media platforms can be found on the providers’ websites:
     • Facebook and Instagram - https://www.facebook.com/privacy/center/
     • TikTok - https://www.tiktok.com/legal/page/eea/privacy-policy/pl-PL
   • In the Store, we use social plug-ins that enable, for example, sharing a product from our Store to your profile / liking our product on Facebook, saving an image from our Website to your Pinterest account. Using such plug-ins involves transferring information from cookies to the owners of these social media platforms:
     • the service provider will receive information that your browser displayed our Website, even if you are not logged in to a given social media platform, or even if you do not have a profile there;
     • if, before visiting our Store, you logged in to one of the above social media platforms, its owner will be able to directly associate your visit to our Website with your profile on that platform.
   • If you do not want social media platforms to associate data collected during your visits to the Store with your social media profile, log out of these platforms before visiting our Website. You can also completely prevent social plug-ins from loading on our Website by selecting the appropriate settings in the cookie consent management panel.
6. Videos
   • Some videos on the Website are embedded using plug-ins from YouTube (a service owned by Google) / plug-ins from Instagram (owned by Meta Platforms) / plug-ins from TikTok. When you play such a video on our Website, Google / Instagram / TikTok receives information about it from your browser, even if you do not have a Google/YouTube account / even if you do not have an Instagram account / even if you do not have a TikTok account, or you are not logged in. If you previously logged in to the above service, the provider will be able to directly associate playing the video with your profile.
   • If you want to prevent Google / Instagram / TikTok from collecting information about your activity on our Website, you can:
     • not play the video (we will treat consent to play a video as consent also concerning other videos on our Website – until you withdraw it, i.e. change your cookie choices),
     • not consent to cookies from that service on our Website,
     • or log out of that service.
   • More information about data processing by YouTube / Instagram / TikTok can be found here / here / here.
   • Some videos on the Website are embedded using Vimeo plug-ins. Therefore, Vimeo cookies are used on our Website, but they are not used for advertising or analytics purposes (they do not track your playback of videos in our Store).
   • More information about data processing by Vimeo can be found here.

# Legal basis regarding cookies

The legal basis for the Store’s use of necessary cookies (indicated above in the section “What cookies do we use?”) is our legitimate interest, i.e. the right to operate a Website that supports our business and the need to maintain its security.
The legal basis for our use of other cookies is your consent.

In connection with our processing of your personal data via cookies, you have the rights described below at any time.

Our use of cookies, in particular for advertising purposes, may involve so-called profiling. This means that we or the marketing companies we use may create a user profile based on the collected information (e.g. e-mail address, order history, device type, technology used, frequency of visits) and on this basis make purchasing predictions for the future. This allows us to decide what content (including ads) to display on our and other websites.

# How long do cookies remain on the user’s device?

It depends on whether they are “persistent” or “session” cookies. Session cookies, i.e. information necessary for browser functionalities to work properly, expire when the user’s session ends, i.e. each time you close our Website. Persistent cookies, which make using the website easier (e.g. remembering the selected resolution, layout, user preferences, recently viewed products) are stored longer by the browser and remain there until they expire, unless you delete them earlier using your browser settings menu.

Cookies of third parties (i.e. analytics, advertising, and social media-related cookies) are subject to their own privacy policies, links to which are provided in this policy.

II. Other purposes of processing personal data of Store users

# What data do we process and for what purposes?

In addition to the cookies described above, we process the following data for the following purposes related to the operation of the Store:

Handling orders in the Store, maintaining customer accounts in the Store	Customer identification and contact data (e-mail address and other data necessary to fulfill the order). Details and history of order fulfillment.	Contract concluded with you as a Store customer - Article 6(1)(b) GDPR
Contacting you, handling inquiries	Identification data and other information you provide in the contact form or other correspondence. Correspondence history.	Our legitimate interest in ensuring communication with persons who send us an inquiry/correspondence - Article 6(1)(f) GDPR
Handling complaints and other after-sales service (e.g. in the event of withdrawal from the contract)	Customer identification and contact data. Details and history of order fulfillment. Correspondence history.	Our legitimate interest in handling complaints and implementing the withdrawal procedure - Article 6(1)(f) GDPR
Archive	All data listed in this table, received from customers and Store users for various purposes	Our legitimate interest in securing data for the purposes of establishing, defending or pursuing claims and for demonstrating compliance with obligations under the GDPR - Article 6(1)(f) GDPR
Accounting, tax purposes	Customer identification and contact data. Invoice details.	Performance of tax obligations under legal provisions - Article 6(1)(c) GDPR
Newsletter	E-mail address. Statistical data related to sent messages, including open history.	Our legitimate interest resulting from your marketing consent - Article 6(1)(f) GDPR
Sales analysis and statistics in the Store	Store sales statistics and user behavior (traffic) statistics on the Website	Our legitimate interest in conducting business analyses to optimize our activity. With regard to traffic statistics on the Website – legitimate interest resulting from your consent to cookies - Article 6(1)(f) GDPR
Marketing purposes	Data about browsing history within the Store, purchase history, demographic characteristics (age, gender, etc.) and other characteristics describing target groups (customer segments)	Our legitimate interest in marketing our own products and services; however, marketing activities involving cookies and/or direct marketing communications addressed to you require your prior consent - Article 6(1)(f) GDPR
Processing purpose	Type of processed data	Legal basis for processing

Providing the above data is not mandatory; however, it is necessary in order to fulfill your order, issue an invoice, notify you about the order status, respond to your inquiry or complaint, etc.

# How long do we process the data?

We process your data related to placing an order in the Store for as long as necessary to fulfill the order, as well as in accordance with accounting and tax regulations.

In addition, we will process the data for the period necessary to achieve the purposes listed above in the table (i.e. until our legitimate interest enabling us to process the data ceases, or until you object to processing, or until you withdraw your marketing consent – if you granted it). Further processing will be possible only if we, as the controller, are subject to a legal obligation (in particular for tax purposes) and possibly also for archiving purposes to protect ourselves against potential claims (until such claims become time-barred).

# To whom do we disclose your data?

In our business, we use services of other cooperating companies; therefore, your data may be entrusted by us to: the company providing us with software to operate the Store, an accounting firm, our Website hosting provider, our e-mail hosting provider, an e-mail marketing system provider, and other companies whose services and marketing tools we use. Your data is also transferred to courier companies and possibly payment intermediaries in order to fulfill your order, and these companies are separate controllers of personal data.

For the marketing activities described above in the “Cookies” section, we use services provided by entities based in the USA (Google, Facebook). Therefore, personal data may be transferred to third countries outside the European Union. An adequate level of protection of your data is ensured by the Data Privacy Framework program, about which you can read more here.

# Your rights regarding data processing

We undertake to respect the confidentiality of your personal data and to ensure that you are able to exercise your rights. You may exercise your rights free of charge by sending us an e-mail message or contacting us in another way.

Please remember that in connection with the processing of your data you have the right to:

• request access to the data we hold about you;
• rectify your data;
• erase your data if it is no longer needed for the purposes for which it was processed or if we have no other legal basis for processing it;
• withdraw consent to the processing of your personal data, if you have given such consent;
• object to the processing of your data if we process it on the basis of a legitimate interest;
• restrict processing;
• lodge a complaint with the President of the Personal Data Protection Office if you believe that we process your data unlawfully.

# Additional information for newsletter subscribers

If you have subscribed to our newsletter, we will send you marketing information about our products and/or services, e.g. news in our offer, promotions, or special offers.

You can unsubscribe at any time by clicking the link included in each newsletter or simply by writing to us.

A modern e-mail marketing system allows us to analyze recipients’ actions, i.e. it provides us with information whether a given message was opened by you. We analyze such information to better tailor the newsletter and notifications to your interests and to send you personalized messages (profiling). You can object to such processing of your data at any time. If a subscriber is inactive for 10 years, we may stop sending them the newsletter. In such a case, we will remove you from our subscriber list (after additional prior notice).

Your data is not used by us to make decisions based on automated processing that could affect your legal situation or produce other similarly significant effects for you.

Further legal information about our newsletter rules can be found in the Newsletter Terms (part of our Store Terms).

APPENDIX NO. 1 TO THE PRIVACY POLICY OF THE Swing Lab STORE
- LIST OF ADVERTISING AND ANALYTICS TOOLS USING COOKIES

1. ANALYTICS COOKIES:
   1. We use Google Analytics
      • Information collected by Google Analytics about users includes, for example: how many times a user visits the website; which subpages they visit; the date of the first and last visit; visit duration; the website from which the user came (referral source); the browser used by the user; the link that was clicked; the user’s location in the world; an anonymized (shortened) IP address, etc.
      • Google assigns each user its own identifier (the so-called Google ID) and stores on its servers data obtained from cookies from various websites. We – as the owner of the Website – may receive from Google reports (statistics) related only to traffic on our Website. These reports naturally include only people who have consented on our Website to having their visits recorded by Google Analytics.
      • Further detailed information about how Google Analytics works can be found here and here.
      • You can also permanently prevent Google Analytics from recording information from your browser by installing a special plug-in available here.
   2. Cookies of the provider of our Store software
      • The software provider through which our Store operates – i.e. the owner of the shoper.pl platform – places cookies on our Website in order to collect aggregate information about how customers use online stores (subpages opened and time spent on them, viewed products, clicks within the Store website, analytics related to purchases, e.g. conversion rates).
      • This data is used to create aggregate reports for e-store owners, containing general (without personal data) information, e.g. which products interest customers of a given store, at what time of year increased traffic or sales occurs, etc. This helps sellers (including us) improve their stores and optimize sales processes.
      • Full information about this can be found in the Cookie policy for visitors to Shoper stores.
2. ADVERTISING COOKIES
   1. We use Google Ads and other Google advertising tools
      • Google stores on its servers data obtained from cookies placed on your device. This data is collected on all websites where you have allowed the use of cookies for advertising purposes by Google (including on our Website), as well as from ads you clicked. Google uses this information to display ads on other websites you visit. Typically, cookies from Google expire after 3 months.
      • As advertisers using Google services, we do not have access to cookie data stored on your device, but we can target ads to audience groups with characteristics selected by us, e.g. all people who visited our website (or a specific subpage) within the last 7 days. This data is only statistical material for us, and we serve ads only based on aggregate criteria (to target groups, not to a specific user).
      • We may also use (as part of using Google Marketing Platform) tools enabling measurement of advertising campaign effectiveness (e.g. how many people clicked on a given ad within a specific period).
      • More about how Google uses cookies to display ads and how you can manage your ad settings can be found here and here.
   2. Meta conversion pixel (Facebook and Instagram)
      • We use the so-called Meta “conversion pixel” (remarketing pixel) to manage ads on Facebook and Instagram.
      • If you consent to this cookie on our Website, then with this tool Meta Platforms services obtain information that you visited our Website. This information is assigned to your profile on that platform if you have one. If you are not a user of these platforms, the information is assigned to a so-called “Facebook ID” created for you.
      • This allows us to serve ads on Facebook and Instagram to people who have already visited our Website or specific subpages (remarketing). We then receive from Meta Platforms only statistical data about ad performance (e.g. how many people saw our ad, how many clicked it), without reference to specific users.
      • If you have a Facebook or Instagram account, we encourage you to read further information about data protection in these services here and here.
      • You can read more about the Meta remarketing pixel here.
   3. E-mail marketing
      • For the newsletter, we use a tool provided by an external company.
      • The e-mail marketing system places cookies on our Website used to display subscription forms and to measure the effectiveness of these forms (conversion rate).