PRIVACY AND COOKIE POLICY

BASIC INFORMATION

Privacy Policy is information regarding the processing of personal data and other information regarding visitors to www.thegloow.com, in particular Users and Customers of the Store, as referred to in the Terms and Conditions. The Privacy Policy defines the principles of processing personal data obtained through the Store.

The purpose of the Privacy Policy is to define the actions taken by Us, regarding personal data collected through the www.thegloow.com website, including Our Store, services and tools, used to perform activities such as creating an Account or placing an Order.

Expressions appearing in the Privacy Policy that begin with a capital letter shall be understood in accordance with the definitions contained in the Terms and Conditions of the online store or the Terms and Conditions of the selected service. Independently below are some terms used in this Privacy Policy:

1. privacy policy - this Privacy Policy,

2. RODO - 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),

3. CONTROLLER OF PERSONAL DATA

The Rich Supplements limited liability company with registered office in Warsaw, address: Krucza 16/22 Street, 00-526 Warsaw, entered in the Register of Entrepreneurs of the National Court Register kept by the District Court for the Capital City of Warsaw in Warsaw, XII Commercial Division, under KRS number: 0001017246, NIP: 7011127593, REGON: 524363636 is the owner of the online sales service of the Assortment available on the website www.thegloow.com and at the same time the Seller in the online store www.thegloow.com.

Hereinafter referred to as "Administrator", "We", "Us").

Contact with the Administrator:

- by mail to the address: 16/22 Krucza Street, 00-526 Warsaw,

- electronically at e-mail address: kontakt@thegloow.com,

- by telephone at: +48 22 250 99 99.

SCOPE, PURPOSE, LEGAL BASIS AND DURATION OF OUR PERSONAL DATA PROCESSING

Account registration

1 Scope of processed data:

In order to set up an Account, we collect and use identification data collected through the registration form, such as your name, and contact information, email address, and the password you choose. The email address is used to log in to www.thegloow.com to your Account.

2 Purpose of data processing:

We use the above personal data to create or maintain your Account.

3 Basis for processing:

The legal basis for the processing of data in the use of your Account is Article 6(1)(b) of the DPA, i.e. the performance of the contract for the operation of your Account in accordance with the Terms and Conditions.

4. Data storage period:

Your personal data contained in the customer profile in your Account will be processed for the duration of the operation of the Account, i.e. for the duration of the provision of the Account service in the Store. At any time you may decide to delete your Account, which will also result in the deletion of your personal data from our database. Remember that deletion of the Account does not result in deletion of data concerning Orders placed through the Store.

Orders

1 Personal Data:

When you make a purchase of our goods from among the available Assortment or wish to make an Order of the "coming soon" Assortment or the "novelty" Assortment, in addition to your identification (such as your name) and contact information (such as your phone number, address or email address), we also collect information regarding your purchases and payments (e.g. information about the goods purchased, the value of the order, the method of payment, billing details and delivery address). We will require this information from you each time you make a purchase without logging into your Account, i.e. without you creating an Account with the Store, or one time when you create an Account.

2 Purpose of data processing:

The processing of the data in the situations specified above will be carried out for the purpose of executing the sales contract or in connection with the intention to conclude it, as well as fulfilling the obligations imposed on Us by applicable laws (e.g. issuing a sales document).

3 Basis of data processing:

The legal basis for the processing of purchase data is the conclusion and performance of a contract to which You are a party, pursuant to Article 6(1)(b) of the DPA.

4. data retention period/criteria for determining the retention period

We process your personal data until the conclusion of the contract, and thereafter, for other lawful purposes related to the contract, e.g. the period for securing possible claims, i.e. until the end of the calendar year in which the relevant limitation period expires. If no contract is concluded, we process your data until the application is processed and for 3 years for possible complaints and claims.

Contact form, hotline, instant messaging, claim submissions

1 Personal information:

Wanting to get in touch with us, you send us a contact form, contact us by phone or using a communicator of your choice, such as Messenger. The data you provide us with include: identification data (such as name and surname) and contact data (such as phone number, address or e-mail address), as well as other information provided in the course of correspondence or conversation.

2 Purpose of data processing:

We use personal data only for the purpose of responding to your inquiries or requests provided in the contact form, during a telephone conversation, conducting a conversation through a selected instant messenger or making a complaint.

3 Basis of data processing:

The legal basis for data processing is Article 6(1)(f) of the RODO. The legitimate interest pursued by The Gloow stems from the desire to respond to your inquiries and requests, and thus to maintain and ensure high customer satisfaction. We maintain complete confidentiality of the personal information you provide when you fill out contact forms, make phone calls or when you contact us via the chat service.

4 Data retention period/criteria for determining the retention period:

We will process your data for the time it takes to handle the question submitted in the contact form, chat, and then, where applicable, for the period of the statute of limitations to protect against possible claims. In the case of complaint requests, we will process personal data until we respond to the complaint request, and then until the end of the calendar year in which the relevant statute of limitations expires in order to protect against possible claims.

In the event that a dispute is pending or a proceeding is in progress, particularly a court proceeding, the retention period will be calculated from the date on which the dispute ends or the proceeding becomes final.

Newsletter

1 Personal data:

When you sign up for the Newsletter in accordance with the Terms of Service "Newsletter", you provide us with your e-mail address. You can also voluntarily provide your name and customize the Newsletter to your needs, in which case we will process your preference information.

2 Purpose of data processing:

Personal data provided as part of the newsletter service is processed for the purpose of sending information containing image and product advertisements, information about news, promotions, sales, special actions, promotions and contests. Keep in mind that this kind of data processing carries with it an analysis of your profile to determine what your preferences are in order to send the appropriate information for you. You can unsubscribe from the newsletter at any time free of charge.

3 Basis of data processing:

The legal basis for the processing of data within the framework of the newsletter mailing is generally the consent given in accordance with Article 6(1)(a) of the DPA.

You may withdraw your consent at any time. Please note, however, that the withdrawal of consent does not affect the processing of your data prior to its withdrawal.

4 Data retention period/criteria for determining the retention period:

If you withdraw your consent to receive the newsletter, your data will be blocked immediately, and then deleted.

Gift Cards | The Gloow Club

1 Personal information:

If you have a Gift Card, we will not process the holder's personal data until you place an order. If you place an order and pay for it using the Gift Card, we will process personal data in accordance with the rules outlined above under "Orders".

2 Purpose of data processing:

The data provided to us by the Purchaser of the Gift Card is processed for the purpose of exercising the Purchaser's rights set forth in the Gift Card Terms and Conditions in connection with the purchase of the Gift Card.

The Gift Card holder's personal data is processed for the purpose of exercising his/her rights under the Gift Card Regulations and in connection with the finalization of the order in case the Gift Card is used to pay for the order.

3 Basis of data processing:

The legal basis for exercising the rights of the Purchaser and the holder of the Gift Card is the Gift Card Rules, so we process the data in order to fulfill the concluded contract in accordance with Article 6(1)(b) of the DPA.

4 Data retention period/criteria for determining the retention period:

We process your personal data until the completion of the contract, and thereafter, for other lawful purposes related to the contract, e.g. the period for securing possible claims, i.e. until the end of the calendar year in which the relevant statute of limitations expires. If a contract is not concluded, we process your data until the application is processed and for the statute of limitations period in order to handle possible complaints and, if justified, to defend against claims.

THE GLOOW CLUB Loyalty Club

1 Personal Data:

If you join THE GLOOW CLUB Loyalty Club, we will process the data required in accordance with THE GLOOW CLUB Loyalty Club Terms and Conditions.

2 Purpose of data processing:

The data provided to us when you join The Gloow Club Loyalty Club is processed for the purpose of exercising the Participant's rights set forth in the Terms and Conditions.

3 Basis of data processing:

The legal basis for exercising the rights of a Participant of The Gloow Club Loyalty Club is the accepted Terms and Conditions, so we process your data for the purpose of fulfilling the concluded agreement in accordance with Article 6(1)(b) of the RODO.

4. Data retention period/criteria for determining the retention period:

In case of cancellation of The Gloow Club Loyalty Club, your data will be immediately blocked and then deleted.

RECIPIENTS OF PERSONAL DATA

Your personal data may be disclosed to third parties that support us in providing the services we offer, including but not limited to suppliers and partners:

1. technology and IT support services (for example, support of our website and other systems we use to provide you with our services),

2. services related to the optimization of our online store order fulfillment processes,

3. providing cloud services and an online store management platform,

4. providing logistics, transportation and delivery services,

5. providing services related to marketing and advertising (including newsletters),

6. providing legal and other specialized services,

7. other services related to customer service.

We provide our suppliers and partners with only the personal information that enables them to provide services to us, and we require them to maintain the confidentiality and security of the information. We also verify that they provide adequate measures to protect your personal information.

In addition, your personal information may be disclosed to entities authorized to obtain it under applicable law, such as law enforcement agencies. To the extent permitted by applicable law, we may also share personal data with debt collection and debt trading institutions.

Data transfer outside the European Economic Area

The level of protection for Personal Data outside the European Economic Area (EEA) differs from that provided by European Union law. For this reason, The Gloow transfers Personal Data outside the EEA only when necessary and with an adequate level of protection, primarily by:

1. cooperating with processors of Personal Data in countries for which a relevant decision of the European Commission has been issued regarding the determination of an adequate level of protection for Personal Data;

2. applying standard contractual clauses issued by the European Commission;

3. cooperation with U.S.-based organizations certified under the Transatlantic Data Privacy Framework adopted by the European Commission.

USE OF COOKIES AND OTHER TECHNOLOGIES

Cookies

We use cookies, which is information sent by the website you visit. They are stored on the terminal device (computer, laptop, smartphone or tablet) you use while browsing the website. We use cookies for:

1. proper configuration of the website - thanks to them it is possible to set the functions and services on the website accordingly,

2. providing security - thanks to these cookies we verify the authenticity and optimize the performance of the site,

3. authentication - thanks to them we know when the user is logged in and we can show him the appropriate content and functionalities,

4. saving session status - they allow us to save information about how the user uses the site. Cookies are also used to save session state and allow, for example, remembering products in the shopping cart, even after closing the browser tab and opening it again,

5. displaying advertisements - these files allow displaying relevant advertising content to users, personalizing advertisements, they are also used to display advertisements outside the website pages,

6. location - they allow to adjust the displayed information to the user's location

7. statistics, auditing, analysis, audience research - they allow us to collect statistical data and create anonymous statistics. This allows us to better understand user preferences. In addition, through appropriate data analysis, we are able to improve and develop our products and services.

Cookies and the information stored in them or accessing them do not cause configuration changes in the device and software installed in this device. The information we obtain through cookies is not attributed to a specific person and does not identify that person. You can change your preference settings here or how your browser uses cookies, including blocking or deleting those from the Website. To do this, change your browser settings.

Cookies and the information stored in them or accessing them do not cause any configuration changes to your device or the software installed on that device. The information we obtain through cookies is not assigned to a specific person and does not allow you to be identified. You can change your browser's use of cookies, including blocking or deleting those from the Website. To do this, change your browser settings.

TYPES OF COOKIES USED ON THE WEBSITE WWW.THEGLOOW.COM

Cookies used on the Website can be divided into two categories:

You can find detailed information about the individual cookies we use in the Cookie Settings. There you can also manage your consents.

The Website uses permanent and session cookies. Below you will find more information about how long they are stored:

Google Analytics

If you consent to the use of Google Analytics cookies through our cookie management banner, we will use these cookies and Google Analytics to collect general and anonymous statistical data that helps us understand how visitors to the Online Store use and interact with our website.

Google Analytics stores information of the following categories: about visits to the website, actions taken on the website, time spent on the website, how visitors arrived at the website, clicks during the visit, as well as information about the browser and device using an anonymous IP address.

Google Analytics has been set up by The Gloow in IP masking mode, that is, to ensure that the IP addresses collected are anonymized. In addition, other Google Analytics settings have been used to ensure that the masked IP address collected from the browser is not combined with any other Google data processing products outside of Google Analytics. However, Google may transfer and process data on its servers in the US.

For more information on how Google Analytics collects and processes data, please visit www.google.com/policies/privacy/partners https://policies.google.com/privacy.

Google Analytics cookies are categorized by us as "Statistical" cookies.

Google Ads

We use Google Ads tools so that we can present our offerings within Google's search engine and on sites that are part of Google's advertising network. A user typing certain search terms into the search engine may see our advertising related to the term typed in. As part of Google Ads, we analyze the effectiveness of ads published on Google sites, which allows us to better match our offer to Users' expectations. When you click on a banner ad published by Google, cookies are saved on your computer as part of Ads.

Google Ads are categorized by us as "Marketing" cookies.

Facebook (Meta) Pixel

Facebook (Meta) Pixel is an o short JavaScript code placed on our site that allows us to measure the effectiveness of ads based on analysis of users' actions on the site. Site users are matched to their Facebook (Meta) accounts and identified by Facebook (Meta) cookies on their devices. Pixel tracks URLs and domains visited, as well as devices used by site visitors. You can view your Facebook ad settings and update your preferences at any time.

Remember:

- Third parties, including Facebook, may use cookies, web beacons and similar technologies to collect or receive information from the Site and other places on the Internet and use it to provide measurement and ad targeting services

- You can disable the collection and use of information for ad targeting services at any time

- you can check the status of your consents and manage your privacy using the following tools: http://www.aboutads.info/choicesoraz http://www.youronlinechoices.eu/

Facebook (Meta) Pixel cookies are categorized by us as "Marketing" cookies.

LinkedIn Ads

We also use cookies as part of LinkedIn's analytics and marketing services.

You can find detailed information about individual LinkedIn cookies in the Cookie Settings and on the LinkedIn page available here.

Microsoft Clarity and Microsoft Advertising

We use Microsoft Clarity and Microsoft Advertising, to record how people use and interact with our website using behavioral indicators, "heat maps" and session replays to improve and market our products and services. Website usage data is captured using our own and third-party cookies and other tracking technologies to determine the popularity of our products, services and online activity. In addition, we use this information for site optimization, fraud, security and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

SALESmanago

The Gloow uses SALESmanago for analytics and marketing purposes. You can find details about Related Cookies in Settings and more information about the service and the provider itself here

MANAGING COOKIES FROM YOUR BROWSER

Most browsers offer the option of accepting or rejecting all cookies, accepting only certain types, or notifying you each time a website tries to save them. You can also easily delete cookies that have already been stored on your device by the browser. Managing and deleting cookies varies depending on the browser you use. See details on cookie management for selected browsers:

- Google Chrome

- Microsoft Internet Explorer

- Firefox

- Safari

- Opera

- Microsoft Edge

For more information on cookie management, click here:

- www.wszystkoociasteczkach.pl or

- www.allaboutcookies.org.

RIGHTS OF DATA SUBJECTS

The data subject has:

1. the right of access (Article 15 RODO), i.e., to request information from The Gloow about the processing of his/her personal data, i.e., to confirm whether personal data about the person is being processed. If data about a person is being processed, he or she is entitled to access it, obtain a copy of it, and obtain the following information: about the purposes of the processing, categories of personal data, information about the recipients or categories of recipients to whom the data have been or will be disclosed, the duration of data retention or the criteria for determining it, the person's rights related to the processing of his or her personal data, the possibility of lodging a complaint with a supervisory authority, the source of acquisition of personal data if not obtained directly from the data subject, and profiling and automated decision processing;

2. the right to rectification (Article 16 of the RODO), i.e., if a person becomes aware that his or her personal data processed by The Gloow is inaccurate, outdated or incomplete, he or she has the right to request that it be promptly rectified or completed;

(3) The right to erasure (Article 17 of the RODO) i.e. he/she may request the erasure of his/her personal data, whereby, if the person has consented to the processing of personal data, the request for erasure will have the same effect as the withdrawal of consent;

4. the right to restrict data processing (Article 18 RODO), i.e. to request the cessation of processing except for storage, in situations where:

a. the data subject questions the accuracy of the personal data;

b. the data subject questions the lawfulness of the processing of personal data by The Gloow;

c. The Gloow no longer needs the data, but the data are needed by the data subject to establish, assert or defend his or her claims;

d. the data subject has objected to the processing and the objection has been recognized by The Gloow;

5. the right to data portability (Article 20 RODO) which means the right to receive the personal data provided to The Gloow in a structured format, for general use, readable by a specific device, so that it can be transmitted directly to another entity, provided that this is technically possible;

6. the right to object to processing (Article 21 RODO) which means the right of the data subject to object to the use of his/her personal data for the purposes of direct marketing of products and services, as well as other marketing activities carried out by The Gloow sent via email or sms). The objection does not result in the deletion of the data, but only in the cessation of its use by The Gloow for marketing purposes.

7 The right to withdraw consent, which means that in cases where the processing of data is carried out on the basis of consent granted, the data subject has the right to withdraw the consents granted for specific purposes of processing at any time. The withdrawal of consent shall not affect the lawfulness of the processing carried out until the withdrawal of consent;

8 The right to lodge a complaint with the competent supervisory authority. If a data subject believes that data is being processed illegally, he or she has the right to lodge a complaint with the competent supervisory authority:

Office for Personal Data Protection

- Ul. Stawki 2, 00-193 Warsaw

- tel. 22 531 03 00, fax. 22 531 03 01

- kancelaria@uodo.gov.pl

CHANGES IN THE PRIVACY POLICY

The provisions of the Privacy Policy may be changed or updated, so we recommend that you regularly follow the changes. We will inform you of any changes or additions by posting relevant information on the Website, and in case of significant changes we may also send you separate notifications to the e-mail address you have indicated.

Publication date: 20.09.2023.