This Privacy Policy defines the principles of processing personal data obtained through the website perlasspain.com, hereinafter referred to as the “Website”).

The owner of the website and at the same time the Data Administrator is Katarzyna Dubiejko, hereinafter referred to as the Administrator.
Personal data collected by the Administrator through the Website are processed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), also referred to as the GDPR.

The Administrator takes special care to respect the privacy of Customers visiting the Website.
1 Type of data processed, purposes and legal basis
The Administrator collects information on natural persons performing legal acts not directly related to their activities, natural persons conducting business or professional activities on their own behalf, and natural persons representing legal persons or organizational units that are not legal persons, to whom the law grants legal capacity, conducting business or professional activities on their own behalf, hereinafter collectively referred to as Customers.
The personal data of Customers are collected in the case of:

using the contact form service on the Website in order to perform a contract provided electronically. Legal basis: necessity to perform the contract for the provision of the contact form service (Article 6, paragraph 1, letter b of the GDPR)

In the event of using the contact form service, the Client provides the following data:

– e-mail address

– name

– telephone number

Additional information may be collected during the use of the Website, in particular: the IP address assigned to the Client’s computer or the external IP address of the Internet provider, domain name, browser type, access time, operating system type.
Navigation data may also be collected from Clients, including information about links and references they decide to click on or other actions taken on the Website. Legal basis – legitimate interest (Article 6, paragraph 1, letter f of the GDPR), consisting in facilitating the use of services provided electronically and improving the functionality of these services.
The transfer of personal data to the Administrator is voluntary.
2 Who is the data shared or entrusted to and how long is it stored?
The Client’s personal data is transferred to service providers used by the Administrator when running the Website. Service providers to whom personal data is transferred, depending on contractual arrangements and circumstances, are either subject to the Administrator’s instructions as to the purposes and methods of processing this data (processors) or independently determine the purposes and methods of their processing (administrators).

1.1. Processors. The Administrator uses suppliers who process personal data only on the Administrator’s instructions. These include, among others, providers providing hosting services, accounting services, marketing systems, systems for analyzing traffic on the Website, systems for analyzing the effectiveness of marketing campaigns

1.2. Administrators. The Administrator uses suppliers who do not act solely on instructions and themselves determine the purposes and methods of using the Clients’ personal data. They provide electronic payment and banking services.

Location. Service providers are based mainly in Poland and other countries of the European Economic Area (EEA).
Customers’ personal data are stored:

3.1. If the basis for processing personal data is consent, then the Customer’s personal data are processed by the Administrator until the consent is revoked, and after the consent is revoked for a period of time corresponding to the limitation period for claims that the Administrator may raise and that may be raised against him. Unless a special provision provides otherwise, the limitation period is six years, and for claims for periodic benefits and claims related to running a business – three years.

3.2. If the basis for processing data is the performance of a contract, then the Customer’s personal data are processed by the Administrator for as long as it is necessary to perform the contract, and after that time for a period corresponding to the limitation period for claims. Unless a special provision provides otherwise, the limitation period is six years, and for claims for periodic benefits and claims related to running a business – three years.

In the event of a request, the Administrator provides personal data to authorized state authorities, in particular organizational units of the Prosecutor’s Office, the Police, the President of the Personal Data Protection Office, the Presidents of the

and the Office of Competition and Consumer Protection or the President of the Office of Electronic Communications.

3 Cookie mechanism, IP address
The website uses small files called cookies. They are saved by the Administrator on the end device of the person visiting the Website, if the web browser allows it. A cookie file usually contains the name of the domain it comes from, its “expiration time” and an individual, randomly selected number identifying this file. Information collected using this type of file helps to tailor the products offered by the Administrator to the individual preferences and actual needs of people visiting the Website.

The Administrator uses two types of cookies:

2.1. Session cookies: after the end of a given browser session or after turning off the computer, the saved information is deleted from the device’s memory. The session cookie mechanism does not allow for downloading any personal data or any confidential information from the Customers’ computers.

2.2. Persistent cookies: they are stored in the memory of the Customer’s end device and remain there until they are deleted or expired. The persistent cookie mechanism does not allow for downloading any personal data or any confidential information from the Customers’ computer.

The Administrator uses its own cookies for the following purposes:

3.1. analyses and research and audience audits, and in particular to create anonymous statistics that help understand how Customers use the Website, which allows for improving its structure and content.

The Administrator uses external cookies for the following purposes:

4.1. presenting a map indicating the location of the Administrator’s office on the Website’s information pages, using the maps.google.com website (external cookie administrator: Google Inc. based in the USA)

The cookie mechanism is safe for the computers of Customers visiting the Website. In particular, it is not possible for viruses or other unwanted software or malware to get into Customers’ computers this way. Nevertheless, Customers have the option of limiting or disabling cookie access to computers in their browsers. If this option is used, it will be possible to use the Website, except for functions that by their nature require cookies.

The Administrator may collect Customers’ IP addresses. An IP address is a number assigned to the computer of a person visiting the Website by the Internet service provider. The IP number enables access to the Internet. In most cases, it is assigned to the computer dynamically, i.e. it changes with each connection to the Internet and is therefore commonly treated as non-personal identifying information. The IP address is used by the Administrator to diagnose technical problems with the server, create statistical analyses (e.g. to determine from which regions we record the most visits), as information useful in administering and improving the Website, as well as for security purposes and possible identification of server-burdening, unwanted automatic programs for browsing the content of the Website.
4 Rights of data subjects
Right to withdraw consent – legal basis: art. 7 sec. 3 GDPR.

1.1. The Customer has the right to withdraw any consent he has granted

1.2. Withdrawal of consent has effect from the moment of withdrawal of consent.

1.3. Withdrawal of consent does not affect the processing carried out by the Administrator in accordance with the law before its withdrawal.

1.4. Withdrawal of consent does not entail any negative consequences for the Client, but may prevent further use of services or functionalities that, according to the law, the Administrator may only provide with consent.

Right to object to data processing – legal basis: art. 21 of the GDPR.

2.1. The Client has the right to object at any time – for reasons related to his/her particular situation – to the processing of his/her personal data, including profiling, if the Administrator processes his/her data based on a legitimate interest, e.g. marketing of the Administrator’s products and services, keeping statistics on the use of individual functionalities of the Website and facilitating the use of the Website, as well as satisfaction surveys.

2.2. Resignation in the form of an e-mail message from receiving marketing communications regarding products or services will mean the Client’s objection to the processing of his/her personal data, including profiling for these purposes.

2.3. If the Customer’s objection proves to be justified, the Administrator will have no other legal basis for processing personal data, the Customer’s personal data will be deleted, the processing of which the Customer has filed an objection.

The right to delete data (“the right to be forgotten”) – legal basis: art. 17 GDPR.

3.1. The Customer has the right to request the deletion of all or some 

3.2. The Customer has the right to request the deletion of personal data if:

3.2.1. the personal data are no longer necessary for the purposes for which they were collected or processed

3.2.2. has withdrawn a specific consent, to the extent that the personal data were processed based on his consent

3.2.3. has objected to the use of his data for marketing purposes

3.2.4. the personal data are processed unlawfully

3.2.5. the personal data must be deleted in order to comply with a legal obligation under EU law or the law of a Member State to which the Controller is subject

3.2.6. the personal data have been collected in connection with the offering of information society services

3.3. Despite the request to delete personal data, in connection with the filing of an objection or withdrawal of consent, the Administrator may retain certain personal data to the extent that processing is necessary to establish, pursue or defend claims, as well as to comply with a legal obligation requiring processing under EU law or the law of a Member State to which the Administrator is subject. This applies in particular to personal data including: first name, last name, e-mail address, which data are retained for the purposes of handling complaints and claims related to the use of the Administrator’s services, or additionally the address of residence/mailing address, order number, which data are retained for the purposes of handling complaints and claims related to concluded sales agreements or the provision of services.

Right to restrict data processing – legal basis: art. 18 of the GDPR.

4.1. The Customer has the right to request the restriction of the processing of his or her personal data. Submitting a request, until it is considered, prevents the use of specific functionalities or services, the use of which will involve the processing of the data covered by the request. The Administrator will also not send any messages, including marketing messages.

4.2. The Customer has the right to request the restriction of the use of personal data in the following cases:

4.2.1. when he/she questions the accuracy of his/her personal data – then the Administrator limits their use for the time needed to verify the accuracy of the data, but no longer than for 7 days

4.2.2. when the processing of data is unlawful, and instead of deleting the data, the Customer requests the restriction of their use

4.2.3. when the personal data are no longer necessary for the purposes for which they were collected or used, but they are needed by the Customer in order to establish, pursue or defend claims

4.2.4. when he has objected to the use of his data – then the restriction is for the time needed to consider whether – due to the special situation – the protection of the Client’s interests, rights and freedoms outweighs the interests pursued by the Administrator in processing the Client’s personal data.

Right of access to data – legal basis: Art. 15 GDPR.

5.1. The Client has the right to obtain confirmation from the Administrator as to whether he is processing personal data, and if so, the Client has the right to:

5.1.1. access his personal data

5.1.2. obtain information about the purposes of processing, categories of personal data processed, recipients or categories of recipients of such data, the planned period of storing the Customer’s data or the criteria for determining this period (when it is not possible to determine the planned period of data processing), the rights of the Customer under the GDPR and the right to lodge a complaint with the supervisory authority, the source of such data, automated decision-making, including profiling, and the security measures applied in connection with the transfer of such data outside the European Union

5.1.3. obtain a copy of your personal data.

The right to rectify data – legal basis: Art. 16 of the GDPR.

6.1. The Customer has the right to request that the Administrator immediately rectify any personal data concerning him that is incorrect. Taking into account the purposes of processing, the Customer whose data is being processed has the right to request that incomplete personal data be supplemented, including by submitting an additional statement, by sending a request to the e-mail address in accordance with §6 of the Privacy Policy.

Right to data portability – legal basis: art. 20 of the GDPR.

7.1. The Customer has the right to receive his/her personal data that he/she has provided to the Administrator, and then send it to another personal data controller of his/her choice. The Customer also has the right to request that the personal data be sent by the Administrator directly to such controller, if technically possible. In such a case, the Administrator will send the Customer’s personal data in the form of a file in the csv format, which is a commonly used, machine-readable format that allows the data received to be sent to another personal data controller.

In the event that the Customer requests the right to in accordance with the above rights, the Administrator shall comply with the request or refuse to comply with it immediately, but no later than within one month of its receipt. However, if – due to the complex nature of the request or the number of requests – the Administrator is unable to comply with the request within one month, it shall comply with it within the next two months, informing the Client in advance within one month of receiving the request – about the intended extension of the deadline and its reasons.
The Client may submit complaints, inquiries and requests to the Administrator regarding the processing of his/her personal data and the implementation of his/her rights.
The Client has the right to lodge a complaint with the President of the Personal Data Protection Office regarding the violation of his/her rights to the protection of personal data or other rights granted under the GDPR.
5 Changes to the Privacy Policy
The Privacy Policy may change, about which the Administrator is not obliged to inform.
Please send questions related to the Privacy Policy to the following address: perlasspain@gmail.com
Date of last modification: 12.02.2025