ПОЛІТИКА КОНФІДЕНЦІЙНОСТІ

Privacy policy

DOCUMENT:


PRIVACY POLICY

VERSION:

01





CONTENTS


  1. GENERAL PROVISIONS


  1. TERMS AND DEFINITIONS


  1. ABOUT THE COMPANY


  1. CATEGORIES OF PERSONAL DATA PROCESSED


  1. COLLECTION AND USE OF PERSONAL DATA


  1. PURPOSES OF USING PERSONAL DATA


  1. PERSONAL DATA RETENTION PERIOD


  1. DISCLOSURE AND TRANSFER OF PERSONAL DATA TO THIRD PARTIES


  1. SECURITY AND RETENTION


  1. CROSS-BORDER DATA TRANSFER


  1. SECURITY OF MINORS


  1. USERS' RIGHTS REGARDING PERSONAL DATA


  1. AUTOMATED DECISION-MAKING


  1. RULES FOR AMENDING THE PRIVACY POLICY

 

Under this Privacy Policy (hereinafter referred to as the Policy), RB ACCESSOIRES LIMITED LIABILITY COMPANY (RB AKCESORIA SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ (RB AKCESORIA SP. Z O.O.)), National Business Registry Number (REGON) 541553154, hereinafter referred to as the Company, defines the principles and mechanisms for working with Users' personal data.


  1. GENERAL PROVISIONS 


  1. The Company ensures the confidentiality and protection of Users' personal data (hereinafter referred to as PD) in accordance with the legal requirements in the field of information protection (GDPR (EU Regulation 2016/679) for users from the EU; CCPA (California Consumer Privacy Act)/CPRA (California Privacy Rights Act), Colorado Privacy Act, Virginia Consumer Data Protection Act, Connecticut Data Privacy Act, Utah Consumer Privacy Act depending on the User's state of residence in the USA, as well as other applicable laws and regulations in the relevant jurisdictions).


  1. General support service: support@ruslanbaginskiy.com


  1. The purpose of this Policy is to transparently inform Users about the collection, processing, storage, and protection of their personal data.


  1. TERMS AND DEFINITIONS


In this Policy, the following terms have the following meanings:


Website means a page on the Internet at the address: https://ruslanbaginskiy.com, created for the presentation and sale of goods by the Seller by means of an electronic transaction. 


Personal data means data or a set of data about an individual by which they can be identified.


User means an individual who has reserved or purchased Goods on the Website and/or an individual who has visited at least one web page of the Website.


Goods means goods and/or services, including gift certificates, that are offered for sale by means of distance communication on the Website. 


Cookie (Cookies/Cookie files) means a text file or files containing a small amount of information that are sent to a web browser and stored on the user's device. Such devices may include a computer, mobile phone, or other device used by the user to visit the Websites.


  1. ABOUT THE COMPANY


  1. RB ACCESSOIRES LIMITED LIABILITY COMPANY (RB AKCESORIA SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ (RB AKCESORIA SP. Z O.O.)), National Business Registry Number (REGON) 541553154, is the owner / administrator of Ruslan Baginskiy online store, designed for ordering and purchasing goods, communicating with the user, and implementing the loyalty program.


  1. The Company respects the private (personal) information of all users who have visited (are visiting) the Website. The Company strives to ensure the protection of Personal Data and to create the most comfortable conditions for using the services.


  1. The Company controls the methods of collecting Personal Data and determines the purposes for which Personal Data is used by the Company. The Company is a “personal data controller”, meaning it determines the purpose of processing personal data, establishes the composition of this personal data, and the procedures for its processing.


  1. The Company processes Personal Data only if at least one of the following grounds exists: (1) the User has given voluntary consent to the processing of their Personal Data; (2) the processing is necessary for the conclusion or performance of a purchase and sale agreement or the provision of services to the user; (3) the processing is required by the legislation of the User's country or is necessary for the Company to comply with its legal obligations.


  1. By registering on the Website, the User confirms their consent to the collection, processing, storage, and use of Personal Data by the Company, including the possibility of transfer to third parties, in accordance with the provisions of this Policy.

 

  1. CATEGORIES OF PERSONAL DATA PROCESSED


  1.  The Company may collect and process the following categories of the User's Personal Data:


  1. Identification data: name, surname, patronymic, sex, date of birth, and other data that allow for the identification of an individual.

  2. Contact and registration data: residential address, phone number, email address, data entered when creating an account on the Website or placing an order, as well as other information voluntarily provided by the User in registration forms.

  3. Information about ordering and reserving goods: data about purchased or reserved goods, their price, payment date, delivery and return conditions, as well as information about related services provided by the Company.

  4. Loyalty program participant data: participant number, bonuses, status and level of participation, as well as other information related to participation in the loyalty program.

  5. Communication with the Company: information about user inquiries to the support service, including emails, messages on social networks and messengers, phone calls; data about the subject of the inquiry, the User's contact details and preferred method of communication. Phone conversations may be recorded to improve service quality, train staff, and prevent abuse.

  6. Technical and automatically collected data: IP address, browser type, operating system, source of referral to the Website, browsing history, purchase data, technical parameters of the website's operation, error reports, unique device identifiers, as well as information collected through cookies and similar technologies about the User's behavior on the Website, including participation in advertising campaigns and opening emails.

  7. Location data and camera access: are collected only with the User's explicit consent.

  8. Information voluntarily provided by the User: comments on social networks (Facebook, Instagram, Telegram, YouTube), completed questionnaires, applications for participation in contests, promotions, or other marketing activities.


  1. Using the Website involves collecting information through cookies and similar technologies. Detailed information is contained in the Cookie Policy.


  1. For special services or events, the Company may collect additional data not covered by this Policy. The User will be informed in advance about the specifics of collecting and using such data.


  1. The Company does NOT collect, process, or store any Personal Data related to the procedure of paying for the Goods through the online payment system installed on the Website. The Company is not responsible for the processing of users' personal data within these payment systems.


  1. COLLECTION AND USE OF PERSONAL DATA


  1. Data ownership and control:

The controller of the Website User's personal data is RB ACCESSOIRES LIMITED LIABILITY COMPANY (RB AKCESORIA SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ (RB AKCESORIA SP. Z O.O.)), (National Business Registry Number (REGON) 541553154, 23, Bohaterów Warszawy Street, office 2, 02-495 Warsaw, e-mail: support@ruslanbaginskiy.com). The Company determines the purposes and methods of processing personal data and is responsible for their protection.


  1. Voluntary provision of data:

The Company processes only the personal data that the User knowingly and voluntarily provides when using the Website. Providing such data is considered as the User's consent to their processing for the purposes defined by this Policy, in accordance with the requirements of the current legislation of the User's country.


  1. Data minimization principle:

The Company limits the collection of personal data to the minimum necessary volume sufficient to fulfill requests and provide services to the User.


  1. Notification about non-mandatory information:

In case of collecting information that is not mandatory, the User will be informed at the time of its provision.

 

  1. Exclusion of sensitive data:

The Company does not collect or process special categories of personal data, which include: racial or ethnic origin, political, religious or philosophical beliefs, membership in political parties or trade unions, information about criminal convictions, health status, sexual life, biometric or genetic data, except in cases expressly provided for by the legislation of the User's country.


  1. Mandatory provision of data and consequences of refusal

The provision of certain personal data by the User is mandatory for the conclusion and execution of a purchase and sale agreement or the provision of services by the Company. Without such data (name, delivery address, e-mail, phone number), the Company will not be able to process the order.


The provision of other data is completely voluntary. Refusal to provide them does not affect the ability to make a purchase but may limit access to personalized offers, discounts, and may also cause the Website to function incorrectly.


The User may withdraw their consent, which does not affect the lawfulness of the Company's processing of the User's personal data that occurred before the withdrawal.


  1. PURPOSES OF USING PERSONAL DATA


Main purposes of processing the Website User's personal data and legal grounds:


Sale of goods and provision of related services 

The User's personal data are processed for placing orders, reserving goods, and delivery. For this purpose, data necessary for the User's identification (name, surname, address, contact details, etc.) are used.


  • Performance of the agreement between the User and the Company;

  • Legal obligations of the Company;

Ensuring the operation of the loyalty program

The User's data are used for accruing bonuses, providing discounts, tracking participation in the loyalty program, as well as for analyzing the history of orders, purchases, and returns of goods.



  • Performance of the agreement between the User and the Company;

Provision of online services and service personalization

The Company analyzes data on the User's interaction with the Website and digital channels, in particular through cookies and similar technologies, to optimize the service and personalize communications.

Statistical and analytical research

Anonymized data are used to assess sales trends, the effectiveness of marketing activities, loyalty programs, and User behavior. Special categories of personal data are not used without the User's explicit consent.


  • Legitimate interest of the Company (service improvement);

Personalized updates and special offers

The Company sends the User information about goods, promotions, and new arrivals based on their interests and order history. Sending is carried out only with the User's consent, which can be withdrawn at any time.


  • User's consent;

Direct marketing and personalized advertising

The Website uses marketing cookies to display personalized advertisements. The User can withdraw consent for the use of such files or opt out of programs on social networks by sending a corresponding request to the Company.


Abandoned cart: if the User interrupts the ordering process, they may receive an email reminder to continue placing the order.


Special target audience: The Company may use the User's data to display personalized advertisements on social networks, in accordance with their consent

  • User's consent;


 

Communication with the User

Personal data are used to process inquiries, complaints, provide consultations and support regarding services and loyalty programs.


  • Performance of the agreement between the User and the Company;

  • Legitimate interest of the Company;

Accounting and fulfillment of legal obligations

The User's data are processed for accounting purposes and to fulfill financial and tax obligations in accordance with the law.


  • Legal obligations of the Company;

Statistical and analytical research

Anonymized data are used to assess sales trends, the effectiveness of marketing activities, loyalty programs, and User behavior. Special categories of personal data are not used without the User's explicit consent.

  • Legitimate interest of the Company (brand and business development);



  1. PERSONAL DATA RETENTION PERIOD


The User's personal data are retained for the period necessary to achieve the purpose of their processing, or until the User withdraws their consent to the processing of personal data, or as provided for by the current legislation of the Republic of Poland and the European Union.


Account data (name, e-mail, phone, address)

3 years from the moment of the last activity.

Order history and accounting documents

5 full tax years.

Data for tax purposes

5 years from the end of the year in which the tax payment deadline expired.

Loyalty program data

3 years from the moment of the last activity or until withdrawal from the program

Marketing consents and cookie files

Until withdrawal

Call recordings and correspondence with the support service

3 years.

Technical data and analytics

No more than 13 months

Data necessary for legal defense or claims

Up to 6 years from the occurrence of the event

After the expiration of the specified periods, the User's personal data are automatically deleted or anonymized so that they cannot be associated with them.


If the User deletes their account on the Website, their personal data are subject to automatic deletion, except in cases where their retention is necessary for the Company to fulfill its legal obligations.


  1. DISCLOSURE AND TRANSFER OF PERSONAL DATA TO THIRD PARTIES


8.1. The Company may disclose or transfer the User's personal data to group companies, loyalty program partners, service providers, and subcontractors for the following purposes: providing ancillary services; ensuring loyalty programs and benefits for Users; conducting statistical research and implementing direct marketing activities; providing Users with access to the services of the Company's partners.


In accordance with the consent provided by the User, the Company may transfer personal data to partners so that the User can use their services integrated into the Company's services. The Company carefully selects partners who are obliged to adhere to their own privacy policies regarding the processing of personal data.


 

8.2. The legislation of the Republic of Poland, the European Union, as well as the legislation of the User's country of residence or the country where the order is fulfilled (in particular, the United States of America, the United Kingdom, or another state), may require the Company to collect and transfer the User's identification data, order information, or other personal data to state authorities, tax or customs services, and law enforcement agencies for tax and customs control purposes.


8.3. The Website may contain links to third-party resources. Following such links is at the User's own risk. The Company's Privacy Policy does not apply to third-party resources. The Company is not responsible for the methods of processing the User's personal data by third parties. For more information, the User should review the privacy policy of the respective third-party resource.


  1. SECURITY AND RETENTION


9.1. The Company applies appropriate technical and organizational measures to protect the User's personal data from unauthorized access, loss, misuse, or unlawful disclosure.


  1. CROSS-BORDER DATA TRANSFER


10.1. As the Company is part of an international network, the User's personal data may be transferred to other countries, including countries outside the European Economic Area. This is necessary to provide Users with the best service, process orders, deliver goods, and for the activities of the Company's partners in various jurisdictions.


10.2. The transfer of personal data to other countries is often necessary for the performance of agreements and the provision of services to the User. In all other cases, the Company ensures an adequate level of data protection in accordance with the requirements of applicable legislation regarding the cross-border transfer of personal data.


10.3. The User understands and agrees that to provide services, their personal data may be transferred to countries outside the European Economic Area, while the Company always applies legally prescribed protective mechanisms that ensure an adequate level of data protection regardless of the User's country.


  1. SECURITY OF MINORS


11.1. The Website is not intended for users under the age of 18. The Company pays increased attention to the security of minors.


11.2. The Company requests that parents or legal guardians familiarize children with potential online threats and explain the purpose and necessity of using the Website's services.


11.3. Only an individual who has reached the age of 18 and has full legal capacity can be a buyer on the Website.


11.4. If a child's legal guardians become aware that the child's personal data has been provided to the Company, such guardians have the right to contact the Company with a request to delete this data. The Company takes the necessary measures to delete it in accordance with current legislation.


  1. USERS' RIGHTS REGARDING PERSONAL DATA


The User has the right to contact the Company to exercise any rights provided for by (EU) Regulation 2016/679 (GDPR), in particular: 


12.1. Right to access


The User can send a request to the Company regarding the existence of the processing of their personal data and receive a copy of such data. The Company also provides information on the purpose of the processing, the categories of personal data, and other necessary information to exercise this right.


 

12.2. Right to rectification.


The User can request the correction of inaccurate or incomplete data. The Company corrects inaccuracies and supplements incomplete personal data in accordance with the purpose of the processing.


12.3. Right to erasure and deletion of data.


The User can request the deletion of their personal data. This includes the deletion of data by the Company and other controllers to whom the data was provided, in accordance with the legislation of the User's country.
Deletion is possible only under legally defined circumstances, when the data is no longer needed for the original purpose of its collection. Due to technical specificities, the deletion process, including backups, may take some time.


12.4. Right to restriction of processing.


The User may request a temporary restriction on the processing of their personal data, for example, when its accuracy is contested. The restriction does not prevent the Company from continuing to retain the data. The Company informs the User about the lifting of the restrictions.


12.5. Right to data portability.


The User has the right to receive their data in a structured, commonly used, and machine-readable format and to transmit it to another controller, insofar as this is technically feasible.


12.6. Right to object.


The User may demand the cessation of the processing of their personal data. This does not apply if the processing is carried out on the basis of the Company's legitimate interest. The User may object to the use of data for direct marketing purposes free of charge. In case of a violation of rights, the User may contact the supervisory authority of their country of residence: 

https://digital-strategy.ec.europa.eu/en/library/list-personal-data-protection-competent-authorities


12.7. Right to withdraw consent.


The User may withdraw their consent to the processing of personal data at any time, for example, by clicking “Unsubscribe” in an email or by changing the Cookie settings on the Website. In certain cases, the Company may refuse to exercise these rights if it is necessary to protect the rights of others or to comply with legal obligations.


Detailed information regarding the rights of US resident Users is contained in Appendix 1 to this Policy

12.9. Contacts for exercising rights.


The User may address questions, requests, comments, or complaints regarding the Privacy Policy or the exercise of their rights to: support@ruslanbaginskiy.com


  1. AUTOMATED DECISION-MAKING


Automated decision-making is a process where computer systems or algorithms independently make decisions without direct human intervention, using pre-programmed rules or artificial intelligence.


The Company does not apply automated decision-making regarding the Website Users.


  1. RULES FOR AMENDING THE PRIVACY POLICY


The Company has the right to periodically amend this Privacy Policy. The changes take effect upon their publication on the Website.


APPENDIX 1 – INFORMATION FOR RESIDENTS OF THE UNITED STATES OF AMERICA 

 

Identification data: name, surname, patronymic, sex, date of birth, and other data that allow for the identification of an individual.


We do not sell or share your identification data. We use it for: 

  • Processing purchases, services, and inquiries; 

  • Personalizing your experience, including sending promotional offers; 

  • Providing customer support and processing your requests under this Policy;

Contact and registration data: residential address, phone number, email address, data entered when creating an account on the Website or placing an order, as well as other information voluntarily provided by the User in registration forms.


We do not sell or share this data. We use it for:

  • Delivering orders and communicating with us;

  • Managing your account;

  • Sending confirmations, updates, and service messages;

Information about ordering and reserving goods: data about purchased or reserved goods, their price, payment date, delivery and return conditions, as well as information about related services provided by the Company.


We do not sell or share your order information. We use it for:

  • Fulfilling and tracking orders;

  • Processing returns and warranty cases;

  • Maintaining accounting and tax records;

Loyalty program participant data: participant number, bonuses, status and level of participation, as well as other information related to participation in the loyalty program.


We do not sell or share this data. We use it for:

  • Accruing bonuses and discounts;

  • Providing personal offers;

  • Tracking your status and level in the loyalty program;

Communication with the Company: information about user inquiries to the support service, including emails, messages on social networks and messengers, phone calls; data about the subject of the inquiry, the User's contact details and preferred method of communication. Phone conversations may be recorded to improve service quality, train staff, and prevent abuse.


We do not sell or share information about our communication with you. We use it for: 

  • Providing customer support;

  • Resolving inquiries and complaints;

  • Improving service quality and training staff (call recordings);

Technical and automatically collected data: IP address, browser type, operating system, source of referral to the Website, browsing history, purchase data, technical parameters of the website's operation, error reports, unique device identifiers, as well as information collected through cookies and similar technologies about the User's behavior on the Website, including participation in advertising campaigns and opening emails.


Some of this data (cookies and pixels) is shared with Meta, Google, and TikTok for targeted advertising - this is considered “sharing” in some US states. We use it for: 

  • Analytics and website improvement;

  • Personalized advertising and retargeting;

  • Measuring campaign effectiveness;

Location data and camera access: are collected only with the User's explicit consent.


We do not sell or share location data (approximate geolocation via IP address is possible). We use it for: 

  • Determining currency and delivery terms;

  • Showing the nearest store;

  • Fraud prevention;

Information voluntarily provided by the User: comments on social networks (Facebook, Instagram, Telegram, YouTube), completed questionnaires, applications for participation in contests, promotions, or other marketing activities.


We do not sell or share this information. We use it for:

  • Improving goods and services;

  • Developing new collections;

  • Personalizing offers and event invitations;


 

The User's personal data may be processed outside the USA, particularly in European Union countries and Ukraine, for order fulfillment, delivery, and customer support. The Company applies the same high level of User data protection in accordance with GDPR and US state laws. 


Rights of US resident users.


Depending on the User's state of residence:


Right of access / Right to know 

Twice a year, the User has the right to receive free of charge, detailed information about the categories of personal data the Company has collected over the preceding 12 months, the sources of collection, the purposes of processing, a list or categories of third parties with whom the Company has shared the data, and the specific data collected. Before providing such information, the Company has the right to verify the User's identity. 


Right of data portability.

In some cases, the User has the right to receive personal data in a portable and readily usable format.


Right to Correct 

The User has the right to request the correction of inaccurate personal data. The Company does not correct data if its retention is necessary to comply with legal obligations, to defend or assert legal claims, or when retention is expressly required or permitted by law.  


Right to Delete 

The User has the right to request the deletion of personal data. The Company has the right not to delete data if its retention is necessary to comply with legal obligations, to defend or assert legal claims, or when retention is expressly required or permitted by law.  


Right to Opt-Out of Sale or Sharing of personal information

The User has the right to opt out of the “sale” or “sharing” of personal data with third parties (as these terms are defined by applicable state law), including the use of advertising cookies and pixels for cross-contextual targeted advertising. 


Right to Opt-Out of Targeted Advertising 

The User has the right to opt out of the processing of their data for targeted advertising purposes. Depending on the User's state of residence, these rights may not apply to pseudonymized data. 

Pseudonymized data is personal data that cannot be attributed to a specific individual without the use of additional information, which is kept separately and is subject to appropriate security measures. 


Right to Limit Use of Sensitive Personal Information 

The User has the right to limit the use of sensitive personal data. 


California resident Users have the right to submit a “Shine the Light” request – once a year, free of charge, to request information about which of the User's personal data was transferred to third parties for direct marketing purposes during the preceding calendar year, as well as the names and addresses of these third parties.


Non-discrimination

The Company does not discriminate against US resident Users in connection with the exercise of any rights provided for by the laws of the US states. A US resident User will not receive worse prices, worse service, or a refusal of service for exercising their rights under this Policy.


To exercise the rights provided for in this Policy, the User shall send a request to support@ruslanbaginskiy.com or call the phone number:/by filling out the electronic form:/with a written request to the address:. The Company has 45 days to respond, with the possibility of an extension for another 45 days for complex requests. In case of refusal to fulfill the request, the User has the right to appeal such refusal.


Right to Appeal

If the Company has refused to fulfill the User's request, the latter has the right to appeal such refusal. To exercise this right, the User must reply to the refusal letter or send a new letter by the means provided for in clause 2.4. of this Appendix.

 

The Company considers the appeal within 45 days of its receipt (with the possibility of an extension for another 45 days).


Submitting a request through a representative (Authorized agent).


The User may authorize another person or company to submit a request on their behalf (hereinafter referred to as the Authorized Representative). To do this, the Authorized Representative must send a written permission or power of attorney and proof of the User's identity (copy of ID, etc.).


Global privacy control (gpc).


The Company respects the Global Privacy Control (GPC) signal, which the User can activate in most modern browsers. If the User has enabled GPC, the Company automatically considers this as the User's refusal to sell and share personal data and targeted (personalized) advertising.


In this case, the User does not need to additionally click “Do Not Sell or Share My Personal Information”.