Privacy policy
Welcome!
If you have come here, you value your privacy. We understand it, and we hand over to you a document with the rules for the processing data, use of cookies, and other tracking technologies present on our website https://www.lula.cleaning
The website administrator is Lula Solutions Sp. z o.o. KRS: 0000977968 NIP: 701−109−35−98, ul. Hoża 29/31,
00 – 521 Warsaw, Poland.
If you have any doubts related to the privacy policy, you can contact us at [email protected].
# 1: Who is the administrator of your data?
The administrator of your data is Lula Solutions Sp. z o.o. KRS: 0000977968 NIP: 701−109−35−98, ul. Hoża 29/31,
00 – 521 Warsaw, Poland.
# 2: Whom can you contact about the processing of your data?
As part of the implementation of data protection in our organization, we have decided not to appoint a personal data protection officer, since, in our situation, it is not mandatory. In matters related to the protection of data and privacy, you can contact us at [email protected].
# 3: What information do we have about you?
Depending on the purpose, we may process the following information about you:
We precisely describe the scope of processed data. It contains each purpose of the processing. More information is provided, in the further part, of this policy.
# 4: How do we receive your data?
You transmit it to us. This happens when:
Some information about you might be automatically collected, by the tools we use:
# 5: Is your data secure?
The security of your data is important to us. We have analyzed the risks associated with the various activities connected with the processing of your data. We take the necessary steps to protect your data. We regularly monitor the state of our technical infrastructure. We train our employees. Besides, we analyze our procedures, and we introduce the necessary improvements. Contact us at [email protected] if you have any questions about your data.
# 6: For what purposes do we process your data?
There is more than just one purpose. Below, there is a list of them, followed by a more detailed description. We have also assigned a specific legal basis in consideration of the above purposes:
User account
To create a user account, you must provide the necessary data, like an email address and password. Providing data is voluntary but necessary to set up an account.
You can provide further data such as name and surname, address of residence, or place of business, tax identification number, telephone number. You can also set your avatar. We use this data when you make an order.
If you set up an account through integration with an account on a social network based on your prior authorization, we will gain access to specific data collected as part of the social network account such as name, email address, profile picture.
Besides, our system for managing accounts saves your IP number when you register a user account.
We integrate Google Analytics tool with the user account mechanism. In this way, the data collected by Google Analytic’s tracking code about your activity on our site is assigned to your user account. The collected data such as
We analyze such information about you, to optimize our websites in terms of user experience, efficiency, and conversion, which is our legitimate interest referred to in article 6, clauses 1, letter f, GDPR. You can modify your data, after the registration of your account. However, if you create an account, using integration with the social network, the data downloaded from this social network cannot be modified. The data provided by you to create the account is processed so you can use your account.
This service provided by a contract concluded on the terms described in the regulations based on article 6, clauses 1, letter b, GDPR. The data will remain on our website for the duration of the user’s account. You can decide to delete your account at any time, but this will not delete information about orders you made and stored in our database. Order’s data in our archives will remain there until the expiry of the limitation period for contractual claims, or the entire duration of the website, due to the possibility of identifying the returning customer, recreating purchasing history, discounts, etc. This is our legitimate interest based on article 6, clause 1, letter f, GDPR.
Orders
To make an order, you should provide data necessary to complete your order. Depending on the order details, the data catalogue may be different. For example, if you order physical products, we must know the address to deliver it to you. If you ask for a VAT invoice for a company, we must know the tax identification number and business address. Providing data is voluntary, but necessary to make an order. Besides, our system used to process the order process records the IP number that you used when placing the order. We save each order in our database. It means that your data is connected with the order, and contains order’s information, such as ordered products, method of payment, method of delivery, date of payment.
Complaints and withdrawal from the contract
You provide data contained in the complaint or withdrawal from the contract. It includes your name, address, telephone number, e‑mail, and bank account number. Providing data is voluntary, but necessary to make a complaint, or withdraw from the contract. The data provided to us, concerning the submission of a complaint, or withdrawal from the contract, carry out the complaint, and withdrawal procedure. We keep it for archival purposes, and it is our legitimate interest based on article 6, paragraph 1, letter f, GDPR. We process the data for the time necessary to complete the complaint or withdrawal procedure. We keep the complaint and documents until the expiry of the warranty period. Statements of withdrawal from the contract will be kept together with the accounting documentation for the period required by law.
Newsletter
You provide your name and email address when you subscribe to the newsletter. Providing data is voluntary, but necessary, to subscribe to the newsletter.
Besides, our system supporting the newsletter records your IP number, determines your approximate location, your e‑mail, and tracks your actions taken after you receive a newsletter from us. You provide data when you subscribe to the newsletter. It is our legitimate interest based on article 6, paragraph 1, letter, f GDPR to process information that does not come from you, but it is collected automatically by our mailing system. It helps to analyze the behaviour of the newsletter subscribers to optimize mailing activities. You can unsubscribe from the newsletter, at any time, by clicking on the dedicated link sent in the newsletter, or simply by contacting us. Despite unsubscribing to the newsletter, your data still will be stored in our database. It will help to identify the returning subscriber. Besides, we keep it, to protect the possible defence of claims related to the newsletter. In particular, to demonstrate the fact that you consented to receive the newsletter and you accepted the date of its withdrawal. It is our legally legitimate interest referred to article 6, clause 1, letter f, GDPR. You can modify your data, at any time, by clicking the link visible in every message sent as part of the newsletter, or simply by contacting us.
Comments and product’s opinions
If you add a comment or product review, you must provide at least the username assigned to the comment or review. The username may contain data, such as name or surname, and email. Providing this data is voluntary, but necessary to add a comment or opinion. You can also add your avatar. It may contain your image. You can also provide the address of your website, but it is not mandatory.
The data provided when you write a comment or opinion will be processed to publish a comment or opinion on the website. The basis for the processing is your consent (Article 6 (1) (a), and it results in publishing your comment or opinion. You can withdraw your consent, at any time, by requesting the removal of the comment or opinion.
Your comment or opinion will be available on the site as long as it is available on the Internet unless you request removal of the comment or opinion first. You can also modify the content of the comment at any time, as well as modify your data.
Correspondence service
If you contact us, you automatically provide your data contained in the correspondence, in particular the email address and name. Providing data is voluntary, but necessary to contact.
In this case, we process the data to contact you. The basis for processing is our legitimate interest based on article 6, clause 1, letter f, GDPR. The legal basis for processing data after contacting you is also our justified purpose of archiving correspondence to ensure that we can prove certain facts in the future (Article 6, paragraph 1, letter f, GDPR).
We might archive the content of correspondence, and we cannot determine when we will delete it. You have the right to request the history of correspondence if it was archived, as well as to request its removal unless it is justified, due to our imperative interests, like defence against potential claims on your part.
Tax and accounting obligations
If we issue an invoice for you, it remains in our accounting records kept for the time required by law. In this situation, we process your data, to fulfill our tax and accounting obligations (Article 6 (1) © of the GDPR concerning the provisions governing tax and accounting obligations).
Archive – details
As part of the description of the individual purposes for the processing of data above, we have indicated the dates of the storage of data. These terms are often associated with the archiving of certain data by us, to ensure that we can prove specific facts in the future, and recreate the course of cooperation with the client, exchanged correspondence, defence, agreements, or claims. We rely on our legitimate interest referred to article 6, clause 1, letter f, GDPR.
Our marketing strategy
As part of our site, we use the mechanism to recover abandoned carts. In a situation where you start the ordering process, but you do not complete it, our system will record this fact to take action, to encourage you to finalize the order.
We might send you an e‑mail to encourage you to finalize the order. We might display a targeted advertisement while you browse the Internet.
Our site can also collect information about your activity, and on this basis, display targeted advertising while you browse the Internet. However, if you are not a registered user, the information used for this purpose is not personal data. Those pieces of information put together with your data from the user’s account, become personal data. We implement the above activities. This implementation refers to individual marketing strategy, article 6, clause 1, letter f, GDPR.
Analysis, statistics, optimization
We collect statistical information on user’s behaviour like browsing our websites, such as following on links, the transition between subpages, time spent on individual pages, etc. We analyze this information to optimize our pages in terms of user experience, efficiency, and conversion. In most cases, the information processed in this way is not personal. The exception is when you are a registered user. Then we can compare this information with your other data collected in the user’s account.
We implement the activities described above based on our legitimate interest referred to the optimization of our websites, article 6, clause 1, letter f, GDPR.
# 7: How long will we keep your data?
Data storage periods have been indicated separately for each processing purpose. You will find this information as part of the details dedicated to each separate processing purpose.
# 8: Who are the recipients of your data?
We will risk the statement that modern business cannot run without the services provided by third parties. We also use such services. Some of these services involve the processing of your data. External service providers who participate in the processing of your data are:
If it is necessary, we might disclose your data to entities, or institutions authorized to gain access to data based on legal rules, such as police, security services, courts, prosecutors.
Besides, we use tools that collect a lot of information about how you use our site. In particular, the following information:
In our opinion, this data is not personal in the nature of things because the external tools that we use collect it. Tool providers also process the data. It is a legitimate action based on their regulations and privacy policies. We use the data to provide and improve services, manage them, develop new services, measure the effectiveness of the advertisement, protect against fraud and abuse. Besides, we personalize the content and advertisement displayed on services, sites, and applications. We have tried to describe the details of individual tools in this section of our policy.
# 9: Do we transfer your data to third countries or international organizations?
Yes, part of the processing of your data may involve their transfer to third countries. We transfer your data to third countries concerning the use of tools that store personal data on servers located in third countries, in particular in the USA. The suppliers of these tools guarantee an adequate level of personal data protection through appropriate compliance mechanisms provided by the GDPR, in particular by joining the Privacy Shield program or using standard contractual clauses. Personal data stored on servers located in third countries as part of the following tool:
Google Ireland Limited provides an adequate level of protection of personal data through the use of compliance mechanisms provided by the GDPR, in particular by joining the Privacy Shield program. Below, there is link to confirmation of participation in the Privacy Shield program, where you can read information about the processing of personal data by this entity.
We also remind you here that we use external tools that may collect anonymous information about you. We have already mentioned this several times as part of this policy, including the answer to the previous question. Suppliers of these tools often use servers located throughout the world to store information, in particular in the United States of America (USA).
# 10: Do we use profiling?
Do we make decisions based on your data? We do not make decisions based on processing, including profiling, that would have legal effects on you or significantly affect you. Yes, we use tools that can take specific actions depending on the information collected as part of the tracking mechanisms, but we believe that these actions do not have a significant impact on you. They do not differentiate your situation as a customer. They do not affect the terms of the contract that you can conclude with us, etc. We can direct to you personalized ads based on previous actions taken by you on our website or suggest products that may interest you. We mean here behavioural advertising. We encourage you to deepen your knowledge of behavioural advertising, in particular regarding privacy issues. Detailed information, together with the ability to manage settings for behavioural advertising, can be found here: http://www.youronlinechoices.com. We emphasize that we do not have access to information that would allow your identification. This data is:
We do not combine the information indicated above with your data stored in our databases. This information is anonymous and does not allow us to identify you. We store this data on the servers of the suppliers of individual tools. These servers can be located all over the world. An exception to the anonymous nature of the information is when you have a user account. Then this information can be combined with your data collected in the user’s account. However, we still do not make decisions based on this data solely on automated processing, including profiling, that would have legal effects on you or similarly significantly affect you. We believe that actions in the area of targeting ads to you depending on your activity on our website and taking optimization actions do not significantly affect you. Therefore, we rely on our legitimate interest referred to article 6, clause 1, letter f, GDPR.
# 11: What rights do you have regarding the processing of your data?
The GDPR grants you the following potential rights, related to the processing of your data:
You can find the description of those rules in detail in article 16 – 21 GDPR. We encourage you to read these regulations. We consider it necessary to explain to you that those rights are not absolute, and you are not entitled to all the processing of your data.
We emphasize that you always have one of the rights indicated above. If you believe that during the processing of your data, we have violated the provisions on the protection of personal data, you have the opportunity to complain to the supervisory body (the President of the Office for Personal Data Protection).
You can always ask us to provide information about data we store about you and for what purposes we process it. Just send a message to the address However, we have made every effort to ensure that we present this information comprehensively in this privacy policy. You can also use the e‑mail address [email protected] provided above if you have any questions related to the processing of your data.
# 12: Do we use cookies, and what are they?
Our website, like almost all other websites, uses cookies. Cookies are small text information stored on your end devices, like a computer, tablet, or smartphone. They should be available to our ICT system (own cookies), or ICT systems of third parties (third-party cookies). Specific information may be saved and stored in cookie files. Then, it can be accessed by ICT systems for specific purposes. At the end of the web browser session, we delete some of the cookies. Other cookies stored on your end device allow us to recognize your browser when you visit the site (persistent cookies) next time. If you want to learn more about cookies, you can find it here: https://pl.wikipedia.org/wiki/HTTP_cookie.
# 13: On what basis do we use cookies?
We use cookies based on your consent, except when cookies are necessary for the proper provision of services by electronic means. Cookies that are not necessary for the proper provision of the electrical service remain blocked until you agree to our use of cookies. During your first visit to our website, we display a message asking you for your consent, together with the option of managing cookies, like deciding which cookies you agree to, and which you want to block.
In terms of your consent to cookies, we accept that you consent by setting your web browser, or additional software supporting the management of cookies. We assume that you agree to all cookies we use that are not blocked by your browser, or additional software that you use.
Remember that disabling or limiting the use of cookies may prevent you from using some of the functions available on our website, and cause difficulties in using our website, as well as from many other websites that use cookies. If you block cookies from social networking plugins, buttons, widgets, and social features implemented on our website, some of the functions may not be available for you.
# 14: Can you disable cookies?
Yes, you can manage cookie settings within your web browser. You can block all or selected cookies. You can also block cookies from specific websites. You can also delete previously saved cookies, and other website and plug-in data.
Web browsers offer the option of incognito mode. You can use it if you do not want to save visited pages and downloaded files in your browsing and history. Cookies in incognito mode get deleted when you close all windows.
Browser plugins, like Ghostery (https://www.ghostery.com), are also available to control cookies.
The option of control over cookie files can be provided by additional software, in particular anti-virus packages, etc.
Besides tools are available on the Internet to control certain types of cookies, and to collectively manage behavioural advertising settings www.youronlinechoices.com/, www.networkadvertising.org/choices.
# 15: For what purposes do we use our cookies?
We use our own cookies to ensure the proper functioning of individual website mechanisms, such as maintaining sessions after logging into the account, remembering recently viewed products, and those added to the basket. Own cookies also store information about the cookie settings defined by you in the cookie management mechanism. Own cookies also support the mechanism of recovery of abandoned baskets.
# 16: What cookies are available?
As part of our functional website
Google Analytics
We use the Google Analytics tool provided by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. We implement activities in this area, based on our legitimate interest, consisting of the production of statistics and their analysis to optimize our website. To use Google Analytics, we have implemented a special Google Analytics tracking code in the code of our website. The tracking code uses Google LLC cookies for the Google Analytics service. You can block Google Analytics tracking code at any time by installing the browser add-on provided by Google: https://tools.google.com/dlpage/gaoptout. Google Analytics automatically collects information about your use of our site. The information collected in this way is most often transmitted to Google servers and can be located all over the world and stored there.
We activated the IP anonymization, and your IP address gets shortened before forwarding. Only in exceptional cases, we transmit the full IP address to Google servers, and it gets shortened there. The anonymized IP address provided by your browser as part of Google Analytics is generally not combined with other Google data.
We emphasize that as part of Google Analytics, we do not collect any data that would allow your identification. Therefore, the data collected as part of Google Analytics are not personal data for us. The information we have access to as part of Google Analytics is, in particular:
Besides, we use the following Advertising Functions as part of Google Analytics:
As part of Advertising Features, we do not collect personal data. The information we have access to:
Google Analytics and Google Analytics 360 services have been certified by the independent security standard ISO 27001. ISO 27001 is one of the most recognized standards in the world and certifies that the systems supporting Google Analytics and Google Analytics 360 meet the relevant requirements. If you are interested in details related to Google’s use of data from websites and applications that use Google services, we encourage you to read this information: https://policies.google.com/technologies/partner-sites.
Google Tag Manager
We use the Google Tag Manager tool provided by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Google Tag Manager enables tags management, like small pieces of code, thanks to which we can control user traffic and behaviour, collect information on ad performance, and take action to improve our site. Google Tag Manager does not collect any information that personally identifies you. However, this tool triggers other tags, which in turn may collect data.
Google AdWords
We use the remarketing functions available as part of the Google AdWords system operated by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. We implement activities in this area based on our legitimate interest. Those activities consist of marketing our products or services.
Google cookie remarketing file is automatically left on your device when you visit our website. Google cookie collects information about your activity on our website. Those pieces of information allow us to advertise within the Google network, depending on your behaviour on our site. For example, if you display a product, information about it is recorded by a cookie remarketing file. It means that we can direct an advertisement for this product or any other that we consider appropriate. This advertisement will be displayed to you within the Google network while you use the Internet, browsing other websites, etc.
We emphasize that, when we use Google Ads, we do not collect any data that would allow your identification. The possible compilation of data acquires the character of personal data. We are no longer responsible for it because Google performs these activities based on a contract concluded with you as a user of Google services.
We can only define the target groups for our ads when we use Google AdWords. Google decides when and how to present our advertisement to you.
Further processing of information only takes place if you have consented to Google to combine your browsing history with your account and to use information from your Google account to personalize ads displayed on websites. In this case, Google will use your data to create and define target group lists for remarketing on different devices. Google temporarily combines the information collected with other data to create target groups.
If you don’t want to receive personalized ads, you can manage your ad settings directly on Google: https://adssettings.google.com/.
If you are interested in details related to Google’s use of data from websites and applications that use Google services, we encourage you to read this information: https://policies.google.com/technologies/partner-sites.
Google AdSense
We display ads on our pages as part of the Google AdSense network operated by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. We implement activities in this area based on our legitimate interest, consisting of monetizing the content we publish.
Our site contains ad tags that instruct your web browser to send a request for advertising content from Google’s servers. Along with the advertising content, the server also sends a cookie. Cookies display ads based on your previous visits to our website or other websites. AdSense also uses cookies to improve the quality of ads. Often applications include target ads based on topics that interest you, improve campaign performance reports, and skip the ads you’ve already seen.
We emphasize that when we use Google AdSense, we do not collect any data that would allow your identification. The possible compilation of data acquires the character of personal data. We are no longer responsible for this because Google performs these activities based on a contract concluded with you as a user of Google services.
Further processing of information only takes place if you have consented to Google to combine your browsing history with your account and to use information from your Google account to personalize ads displayed on websites. In this case, Google will use your data to create and define target group lists for remarketing on different devices. Google temporarily combines the information collected with other data to create target groups.
If you don’t want to receive personalized ads, you can manage your ad settings directly on Google: https://adssettings.google.com/.
If you are interested in details related to Google’s use of data from websites and applications that use Google services, we encourage you to read this information: https://policies.google.com/technologies/partner-sites.
Facebook Custom Audiences
As part of the Facebook Ads system provided by Facebook Inc., 1601 S. California Ave., Palo Alto, CA 94304, USA, we use the function of Custom Audience Groups to target specific groups of users of targeted advertising messages. We implement activities in this area based on our legitimate interest, which consists of marketing our products or services.
To target personalized ads in terms of your behaviour on our site, we have implemented Facebook Pixel as part of our site. It automatically collects information about your use of our site. Facebook servers receive this information. Those servers may be located all over the world, in particular in the United States of America (USA).
The information collected as part of Facebook Pixel is anonymous. It does not allow us to identify you. Depending on your activity on our pages, you can reach a specific group of recipients, but we do not identify individual people belonging to these groups.
However, we would like to inform you that Facebook may combine the information collected with other information about you collected as part of your use of Facebook. Facebook can use it for its purposes, including marketing. Such Facebook actions are no longer dependent on us, and you can search for information directly in Facebook’s privacy policy: https://www.facebook.com/privacy/explanation. You can also manage your privacy settings from your Facebook account. Here you will find useful information: https://www.facebook.com/ads/settings.
Social tools
Our website uses plugins, buttons, and other social network plugins. They are available at social networking sites, such as Facebook, Instagram, Linkedin, Twitter, Pinterest.
If you display our website with a plug-in for social network websites, your browser sends information about your visits to the administrator of those social websites. The plug-in is a fragment of a social network site built into our site. The browser sends information about the request to download the content of the social networking site onto our site.
The plugins collect certain information about you, such as your user ID, website visited, date and time, and other information about your web browser.
Social network administrators use some of this information to personalize the viewing conditions on our site. For example, when you visit a page with a „Like” button, the administrator of the social network needs information about who you are to show you which of your friends also like our site.
Plugins collect pieces of information. Social network administrators can use them for purposes, such as improving their products, creating user profiles, analyzing and optimizing their activities, targeting ads. We have no real impact on how social network administrators use these pieces of information. You can search for details in the regulations and privacy policies of individual social networking sites.
Social network plugins collect and transfer information to the administrators of these websites even when you browse our site without being logged into your account on the social network. Then the browser sends a more limited set of information.
If you have logged into one of the social networking sites, then the website administrator will be able to directly assign a visit to our website to your profile on the given social networking site.
If you do not want social networking sites to match the data collected during your visits to our website directly to your profile on a given website, you must log out of this website before visiting our website. You can also completely prevent the plugins from loading on the page by using the appropriate extensions for your browser, like script blocking.
To find out more about the processing of information collected by the administrators of social networking sites, such as the scope of data collection, data processing, your rights, settings protecting your privacy, you will find everything in the privacy policies of individual service providers:
YouTube
Our widgets embedded with YouTube widgets allow you to play recordings available on YouTube directly from our pages. Google LLC operates YouTube.
The videos are in the privacy protection mode on the website.Google does not collect any information about you and does not save any cookies on your device until you play the recording. This is information provided by YouTube.
If you play a recording, YouTube stores cookies on your device, and receives information about the source of the recording, even if you do not have a Google account, or you are not logged into the account. If you are, the service provider can directly assign a visit to our website to your account. In the Google privacy policy, you can find a description:
The information collected as part of cookies related to YouTube videos embedded on our pages is used by Google to ensure the correct and safe functioning of the widget, analysis, and optimization in the field of services provided by YouTube, as well as for personalization and advertising.
Remember that by playing recordings available on YouTube, you use the services provided electronically by Google LLC. Google LLC is an independent entity independent of us providing electronic services to you. Details of YouTube’s terms of use, including privacy, can be found in documents shared directly by YouTube:
# 17: Do we track your behaviour on our site?
Yes, we use Google Analytics, Google AdWords, Hotjar, and Facebook Custom Audiences tools, which collect information about your activities on our site. These tools are described in detail as part of the question about third party cookies, so we will not repeat this information here.
here.
# 18: Do we target you with targeted ads?
Yes, we use Facebook Ads and Google Ads. Therefore, we can target ads for specific target groups based on various criteria, such as age, gender, interests, profession, work, activities previously undertaken on our site.
You can find the description of these tools in detail as part of the question about third party cookies, so we will not repeat this information here.
# 19: How can you manage your privacy?
The answer to this question you can find in many places of this privacy policy like in part about individual tools, behavioural advertising, cookies consent, etc. However, for your convenience, we have collected this information again in one place. Below, you can find a list of options for managing your privacy:
# 20: What are server logs?
Website use involves sending queries to the server that stores the website’s content. The server’s logs save each query. Logs include Your IP address, server date and time, information about the web browser, and your operating system. The server saves and stores logs. The saved data is not associated with specific users of the site, and we do not use it to identify you. Server logs are only auxiliary materials to administer the site, and no one has access to its content, except for persons authorized to administer the server.
# 21: Do you want to find out more?
Data processing, the use of cookies, and the management of privacy is a
complex problem. We ensured that this document provides the broadest possible knowledge about matters important to you. If anything is unclear, you want to learn more, or just to talk about your privacy, contact us at [email protected].
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