Privacy and cookies policy
Privacy policy for shop users Valid as of 11.03.2024.
As of 25 May 2018, the new Data Protection Regulation (RODO) applies across the European Union. In this document, we describe the services we provide and explain how we protect your privacy. We also write about how you can exercise your rights over the data we have collected.
Personal data controller
The administrator of your personal data within the meaning of Article 4(7) RODO is Trade Tech Sp. z o.o. with its registered office at: ul. Nowowiejska 1/3 lok.9, 00-643 Warsaw ("Administrator"); entered in the register of entrepreneurs kept by the District Court for the Capital City of Warsaw, XIII Economic Division of the National Court Register under the number 0000814937, REGON: 384908450 , NIP: 7010956229, (hereinafter referred to as "Administrator").
For all matters relating to the processing of your personal data, you may contact the Controller at the above-mentioned registered office address or via e-mail biuro@systemybofa.pl
How we take care of your privacy
In the privacy policy we describe how we protect your privacy and your personal data that you provide to us when on the shop site:
- you use the shop service,
- you are shopping,
- you benefit from additional services,
- you do other activities.
In the privacy policy we define the purposes, scope and grounds on which, we process your personal data. We secure your data using technical and organisational measures that are appropriate to the possible risks and categories of data. In particular, we take into account the risks that arise from:
- accidental or unlawful destruction of data;
- loss, modification or unauthorised disclosure of data;
- unauthorised access to personal data.
Please note that some of the services we offer will redirect you to websites or services where there are other controllers of your personal data. This occurs if you make a payment or use a service that we do not offer directly.
These entities are independent of us and are separate data controllers. The terms on which they provide their services, and how they protect your personal data, can be found in the regulations, policies or other documents that the entity will indicate.
For more information, see the chapters:
- Data processing principles;
- Recipients of data and transfer of personal data to countries outside the European Economic Area.
[Legal basis for data processing: 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), Personal Data Protection Act of 10 May 2018].
Scope and means of processing your data
Depending on which services and functionalities you use, we will process your data.
In order to process your orders and returns, to send you notifications about the status of your order and to resolve any problems that may arise, we need your data. We also use personal data when we manage your payments and process complaints and warranty claims that relate to your orders.
With personal data, we receive the information necessary to complete the purchasing process.
Depending on what you do on the website or app, we may collect different sets of personal data. Below we set out what data we process and for what purpose, and you can find more information about this in section 3 Personal data processing principles - purposes, grounds and duration of processing of your data.
When you visit our online shop
If you are a person who already has an account with us and is logged in, we can identify you from the data that is available in your account in the Customer Area.
You can also shop as a guest (non-logged-in customer), in which case we will require from you the data necessary so that we can send and deliver your order:
- name,
- delivery address,
- email address,
- telephone number,
- Invoice data, if different from the delivery address.
When you register an account in the customer area
- name,
- email address,
- account password.
This is a standard set of data for any individual. If you do not provide us with this data we will not create a shop account for you.
When you use your account in the customer area
When you use your account, you have access to a user panel where you can complete, check and change your data. You can also manage the consents you give.
You can save the data you need to shop in your account:
- delivery address,
- telephone number,
- Invoice data, if different from the delivery address.
You can also fill in the data that enables you to make use of the services we offer when purchasing certain products. The data you provide in this case depends on the type of service and whether we or our partner offers it.
By using your Customer Zone account you also have the option of:
- pay for the purchase via a payment operator;
- share your opinion on your purchases;
- use the knowledge base;
- use video material;
When you use your account we collect additional information about you:
- purchase history,
- history of additional services,
- preferred and used forms of payment,
- the data you use to issue a proof of purchase,
- shipping details,
- payment statuses,
- comments and opinions that relate to the transaction.
When you make a claim to exchange or return a product
If you wish to make use of the guarantee, warranty or return a product, please use our form on the service page. Once you have done so, we will register and process your request.
If you fill in the form as a logged-in customer or know your receipt or invoice number, we will complete the data we already have.
If you are filling in the form as a guest, you will need to provide the data yourself:
- name,
- company name,
- address,
- email address,
- telephone number,
- bank account number on return.
- invoice number
When you use the additional services we offer such as the PRO Guarantee
On the product page, you will always find information on which additional services you can use when you buy a product. We highlight both the services you can buy immediately and those you can buy later when you need them.
Depending on the option you choose, we will require additional data from you. For example, the delivery address, installation or repair of the product, as well as the data you need in order to purchase additional servicing of the equipment. We will ask you for this data after contacting you by telephone.
When you use accompanying services that are offered by our partners, when you make payments
When you pay cashless you use services provided by our partners, who process certain personal data that are necessary to complete the transaction.
When you use the contact form, send a traditional email to us, call or chat
You can contact us through various channels. Depending on which form of contact you choose, we will ask you for a different set of data.
You can get in touch:
- by email - you send an email from your mailbox or via our form, providing us with your email address and other details you provide in the message;
- by telephone - you give us your telephone number and any other details the adviser asks for to verify who they are speaking to, resolve the problem, provide information about the order;
- via chat - you give us your nickname and any other details you send.
Please note that, as part of our customer-user service, we can use the contact details you have added to your customer panel in your Customer Area account.
We record our conversations, and save chats and emails, we do this to handle the issue you raise.
When you are our partner, contractor or collaborate with us in some way
If you are our partner, contractor or collaborator, we will process your contact and representation data. These include:
- name,
- position,
- telephone number,
- email address.
We will use this data to contact you, sign and execute the contract and for representation purposes.
Cookies
Like most websites, we also use so-called cookies. These files:
- are stored on your device (computer, telephone, etc.)
- enable, among other things, the use of all website functions
- do not alter the settings of your device
Using the appropriate options of your browser, you can at any time:
- delete cookies
- block the future use of cookies
On the website, cookies are used for:
- storing information about your session
- statistical
- marketing
- making available the functions of the Site
Processing of personal data in connection with parties' claims
We may process your personal data when we are pursuing our claims and rights or defending against claims that you have made against us.
For this purpose, we will process data that is necessary to process or defend against a claim.
We will process your data until the case is concluded or the judgment becomes final. While the claim is being processed, we will not delete your data even if you ask us to do so.
[legal basis: Article 6(1)(f) RODO].
Principles of personal data processing - purposes, grounds and duration of processing of your data
We need your data to:
- handle your orders,
- send you notifications about the status of your order,
- resolve any delivery problems,
- prepare an offer for you or offer additional services.
We also use your personal data when we manage your payments, handle warranty claims and returns on products you have ordered.
With personal data, we obtain the information necessary to complete the purchasing process. In addition, on their basis we can:
- identify you and check whether your age qualifies you for online shopping;
- confirm your address with external parties.
We will process your data for as long as you are an active customer of ours.
As we take care of the continuity of supply and availability of products for all customers, we may, in accordance with the rules set out in the Terms and Conditions of Sale, limit (temporarily) your ability to purchase certain products or even assortment groups (for example, we may set a maximum number of items you can purchase). In this case, we process your personal data in accordance with Article 6(1)(b) of the RODO, which means that we will not delete your personal data, even if you request it, until we remove the restriction.
Please note that if you return a product or return it to us as part of a warranty claim you are obliged to delete all your data from the device, including any personal data that is there. We are not responsible for the data you leave on it. You, as the owner of this data, are responsible for delivering the device to us without any private data, including personal data. If you fail to do so, we may delete your data.
If you are using a manufacturer's warranty and we are the intermediary who passes on your equipment as part of the warranty claim, we can pass on your device, to the manufacturer's third-party service, together with your data - including personal data.
If you are unable to delete the data for technical reasons (e.g. the equipment does not start up and you are therefore unable to delete the data that is on it), please notify us in each case before handing over the equipment.
We may process the following personal data in the course of your purchase and after-sales service:
- contact and mailing details: name, address, e-mail address and telephone number;
- payment information and payment history;
- information on hire purchase, leasing and rental;
- procurement information;
- information on complaints and returns or cancelled orders.
See the table below for details:
| Category or type of personal data | Processing purposes | Legal basis | Storage period |
|
Account registration in the Customer Area. | Article 6(1)(b) RODO | Until you cancel our services. |
|
User account maintenance in the Customer Area.
Purchase handling including order status and delivery information for logged-in customers. |
Article 6(1)(b) RODO | Until you cancel our services. |
|
Handling of purchases, including information on order status and delivery for customers who are not logged in. | Article 6(1)(b) RODO | Until the order is delivered, including the time for returning the product. |
|
Handling sales of the additional services we provide, for example: the PRO warranty - extra protection that guarantees service and repair of equipment. | Article 6(1)(b) RODO, in relation to consent to be contacted. | Until you cancel our services. |
|
Issuing documents that relate to sales - VAT invoices, correction invoices, notes. Statutory obligations relating to tax returns and accounting obligations. | Article 6(1)(c) of the DPA in conjunction with Article 74 of the Accounting Act and Article 70 § 1 of the Tax Ordinance. | For 5 years, from the end of the year in which the event creating the legal obligation to which the documents were issued took place. |
|
Individual customer account settings in the control panel. | Article 6(1)(a) RODO | Until you change your individual settings, i.e. withdraw your consent. |
|
Handling of complaints, returns and warranties, including information on the status of the request. | Article 6(1)(c) RODO in connection with the Consumer Rights Act and the Civil Code. | A maximum of 2 years after completion of the application service. |
|
Handling complaints and technical problems related to the operation of the shop website and or customer account. | Article 6(1)(f) RODO | Pending final resolution of the case. |
|
The administrator's legitimate interest in the collection of debts or in conducting and handling litigation, mediation and arbitration. | Article 6(1)(f) RODO | 2 years from the date of final disposal of the case |
|
Archiving of electronic and paper documentation. | Article 6(1)(c) RODO | For the period that the law requires, or if the law does not specify such a period, for the time that their storage is within the administrator's legitimate interest, regulated by the time of redress. |
You can pay for purchases you make in our shop cashless in a number of ways.
If you choose a cashless payment method, you agree that we will pass on your data to our partners who are cashless payment operators. They need your data to process your payment and other services you use.
When we transfer your data the payment operator becomes the controller of your data, we are a separate controller and process the information about which payment method you have chosen.
The payment provider should provide you with an information clause about how it processes your personal data. It can do this as text on the payment form or add it as an attachment. It can also refer you to its website or service where you can find this information.
Below you will find information on for what purpose, for how long and on what basis we process your data when you use the services of our partners:
Category or type of personal data:
- name
- address
- company name
- registered office address
- bank account number
- information on the chosen method of payment
- payment history
Processing purposes
To provide the payment services we offer for cashless payments, i.e. to improve the quality of services.
Legal basis
Article 6(1)(b) RODO in connection with the choice of a particular payment method
Storage period
Until the service is terminated or an effective objection is made.
Contact form and other forms of handling customer requests
We process your data if you contact us:
- via the contact form,
- in the chat room,
- by email,
- by telephone,
- via social media.
In the table below, you will find details of such processing:
| Category or type of personal data | Processing purposes | Legal basis | Storage period |
Contact form:
|
Contact with the customer for purposes related to the performance of the contract or the provision of additional services. | Article 6(1)(b) RODO | Until you cancel our services. |
| The controller's legitimate interest in handling a customer request that is not directly related to the contract. | Article 6(1)(f) RODO | Until the final case is settled or an effective objection is lodged. | |
A message that was sent by email:
|
Contact with the customer for purposes related to the performance of the contract or the provision of additional services. | Article 6(1)(b) RODO | Until you cancel our services. |
| The controller's legitimate interest in handling a customer request that is not directly related to the contract. | Article 6(1)(f) RODO | Until the final case is settled or an effective objection is lodged. | |
Contact via the helpline:
|
Contact with the customer for purposes related to the performance of the contract or the provision of additional services. | Article 6(1)(b) RODO | Until you cancel our services. |
| The controller's legitimate interest in handling a customer request that is not directly related to the contract. | Article 6(1)(f) RODO | Until the final case is settled or an effective objection is lodged. | |
Contact via chat
|
Contact with the customer for the purpose of contract performance or the provision of additional services . | Article 6(1)(b) RODO | Until you cancel our services. |
| The controller's legitimate interest in handling a customer request that is not directly related to the contract. | Article 6(1)(f) RODO | Until the final case is settled or an effective objection is lodged. | |
Other forms of contact, for example, a private message sent via social media
|
Contact with the customer for purposes related to the performance of the contract or the provision of additional services. | Article 6(1)(b) RODO | Until you cancel our services. |
| The controller's legitimate interest in handling a customer request that is not directly related to the contract. | Article 6(1)(f) RODO | Until the final case is settled or an effective objection is lodged. |
Processing of the data of our partners, contractors, collaborators in connection with the mutual cooperation of the parties (establishment of cooperation, signing and supervision of the correct execution of the contract, dedicated training)
Data processing in marketing
Processing of data in connection with the execution of requests under the RODO
In part four of the Privacy Policy, we describe what rights you have under the RODO. If you send or submit a request to us, we process your personal data contained therein. We store the content of such a request for evidential purposes.
We will not delete your data if we are in the process of preparing your order or clarifying an issue with you, related to purchases and services you use.
Below is how we process your personal data when we handle your requests:
| Category or type of personal data | Processing purposes | Legal basis | Storage period |
|
Implementation of the request according to the scope indicated by the applicant. Concerns the following articles of the RODO: -art. 7(3), Art. 15, Art. 16, Art. 17, Art. 18, Art. 19, Art. 20, Art. 21 Taking into account the principle of accountability (need to archive for evidentiary purposes in relation to the records kept). | Article 6(1)(c) of the RODO in conjunction with the indicated articles of the RODO, i.e. Article 7(3), Article 15, Article 16, Article 17, Article 18, Article 19, Article 20, Article 21. | For a maximum period of 6 years from the date on which the application was submitted. |
Processing of data in connection with parties' claims
We may process your data when we are handling claims, both those made by you and those we are pursuing ourselves.
The extent of the data processed depends on what the claim concerns. We always process only the data that is necessary to process the case.
An example set of such data is presented in the table below.
| Category or type of personal data | Processing purposes | Legal basis | Storage period |
|
The controller's legitimate interest in pursuing or defending against claims. | Article 6(1)(f) RODO | Pending a final settlement of the case, including an administrative decision or court judgment becoming final. |
In the case of natural persons who are self-employed or partners in partnerships, additionally:
|
Security of our services, monitoring compliance with the regulations.
We constantly monitor our systems to ensure the security of customers who shop with us or use our services. To this end, we may obtain and record your personal data that we receive on our servers from web browsers or apps when you use our shop. In this way, we can detect threats and ensure the security of traffic on the website and mobile app.
In addition, we continuously check that website users comply with the law, including our terms and conditions.
Any actions aimed at circumventing the law, circumventing the observance of the Terms and Conditions, aiming at fraud, scamming, actions violating good morals will be blocked and consequences will be drawn against such user.
| Category or type of personal data | Processing purposes | Legal basis | Storage period |
Data, linked to the personal data we have in the system:
|
To promote the security of electronic services and the safety of users, to counteract abuse, including fraud, actions in breach of public decency aimed at circumventing the law or the provisions of the Terms and Conditions and to ensure traffic safety. | Article 6(1)(f) RODO | Until the services are terminated. |
Exclusion of liability
We are not responsible for the incorrect processing of personal data and related processes if your personal data is made available to unauthorised persons or entities as a result of one or more of the following situations:
- the data we have received from you is incorrect, e.g. wrong e-mail address, wrong phone number, wrong shipping address;
- you are using a public computer, which increases the risk of data leakage and lack of personalised settings (e.g. browsers), or you are using a profile or device that is not yours - it operates according to the owner's settings;
- Your email address has been hijacked (e.g. as a result of a cyber attack or inadequate security), so that your password for your account with us has been obtained by an outsider;
- by your negligence, e.g. by leaving your logged-in session on a public device, by you passing your password to another person, by using a password with a different strength than the maximum suggested by the website when you set up your account, by using the same password on different services, or by malware on your device;
- your data being made available to third parties to collect an order, make a complaint or carry out another process in our shop, leading to an incident;
- data leaks due to the mistakes of our partners who were administrators of your data in the process, e.g. carriers, couriers, banks, financial institutions and others.
Your rights in the context of RODO
Trade Tech Sp. z o.o. exercises your rights that arise from the RODO, including those described in Articles 15-22 of the RODO.
If you wish to exercise your rights, please email our Data Protection Officer at iod@systemybofa.pl or by any other means you choose. You will find contact details in Section 7 of the Policy.
Below you will find a description of your rights:
Right of access Article 15 RODO
You have the right to check which of your personal data we process at any time, to find out:
- what their scope is;
- for which purposes they are processed;
- on which legal basis we process them;
- to whom we make them available;
- what is the planned duration of their storage.
If you wish you can receive a copy of your data from us - to do so please contact us.
Right to rectification of data Article 16 RODO
You have the right to correct or complete your personal data in case it is incomplete or incorrect. If you have an account in the x-kom shop, you can correct or complete your personal data yourself at any time in the settings. You can also contact us to do this.
Right to erasure (right to be forgotten) Article 17 RODO
You have the right at any time to delete your personal data that we process (be forgotten). To do so, use the special button that is available when you log in to your account or contact us in another way that is convenient for you.
The exception is when:
- you have an open order - not yet shipped or only partially shipped;
- We look forward to receiving your payment, regardless of payment method;
- you are a person who has made a purchase in our shop - in which case we will retain your personal data relating to the transaction for reporting and accounting purposes, including evidence;
- if you have bought a product from us that we have placed a temporary restriction on its sale, e.g. in terms of quantity, because it is not readily available on the market - in which case we will not be able to delete your data until we remove the restriction (we store the data necessary to determine whether you have already bought a restricted product from us);
- if we are obliged to secure your data on the basis of a request made to us by an authorised state authority, e.g. the police, the public prosecution service, a court, etc;
- If your data is necessary for the establishment, investigation or defence of claims.
Right to restrict processing Article 18 RODO
You can request that we restrict the processing of your personal data when:
- you do not consent to us processing your data on the basis of a legitimate interest of the controller. We will restrict processing if we determine that your rights override our legitimate interest;
- you report that your personal data is incorrect. We will restrict the processing of your data until we have verified its accuracy;
- processing is unlawful. In that case, you may not agree to the deletion of your personal data and instead request the restriction of the use of your personal data;
- we no longer need your personal data, but they are needed by you to establish, assert or defend your claims.
To exercise this right, please contact us.
Obligation to notify rectification or erasure of data or restriction of processing Article 19 RODO
If you request this, we will inform you who is the recipient of your personal data.
We are obliged to inform about the rectification, erasure or restriction of the processing, to anyone to whom we have communicated the data, if this is possible or does not require a disproportionate effort.
[legal basis: Article 16,17 or 18 RODO].
Right to data portability Article 20 RODO
You can exercise your right to portability when we process your personal data by automated means on the basis of your consent or a contract concluded with you. You have the right to receive a copy of your data from us in a structured, commonly used and readable format.
We may send a copy of this directly to you or to another entity that will henceforth process the data. Please note that this only applies to personal data we have from you. If you would like a copy of your data, please contact us.
Right to object Article 21 RODO
You have the right to object to the processing of your data to the extent that we do so on the basis of a legitimate interest of the controller. Such an objection should be justified by you. When you object, we will stop processing your personal data until we determine whether your rights override our interest.
We will not stop processing your data when legally your interest or your rights are cancelled or there are legal claims against you. In such circumstances, we will inform you.
You do not need to substantiate your objection if it concerns the processing of data for direct marketing purposes, including profiling.
Right not to be subject to automated processing, including profiling Article 22 RODO
You have the right not to give us consent to automated decision-making in relation to your personal data, including profiling, that produces legal effects against you or similarly affects you significantly. You can withdraw your consent yourself if you have an account with us - under the "settings" tab. If you do not have an account please contact us and notify us of the withdrawal of consent.
To effectively exercise your right to object to the profiling of your personal data, you must log out of all devices and delete all cookies, including browsers (the deletion process can take up to 48 hours). You can find out how to delete cookies correctly in the cookie policy.
Right to lodge a complaint with a supervisory authority Article 77 RODO
If you believe that we are processing your personal data inappropriately you have the right to lodge a complaint with the supervisory authority, the Office for the Protection of Personal Data, based in Warsaw at Stawki 2, 00-193 Warsaw, details can be found on the office's website.
You can also always contact us if you believe that we are incorrectly processing your personal data.
Right not to give consent and to withdraw consent at any time
If the processing of your data requires your consent you have the right not to give it. Such situations occur, for example, when we ask you whether you want to receive marketing information from us.
You always have the right to withdraw any consent you have given at any time on the basis of Article 7(3) RODO e.g. for marketing activities, profiling, bearing in mind that the withdrawal of consent does not affect the lawfulness of the processing carried out on the basis of the consent given before its withdrawal.
Cookie policy and similar technologies
The website uses technology to collect cookies, including IP address, tracking pixels, local data including globalisation data or push notifications.
Recipients of data and transfers of personal data to countries outside the European Economic Area
We may pass on the data you provide to other entities, such as companies that provide certain services for us. These entities will process your personal data on the basis of a contract with us and only to the extent that we instruct them to do so. These entities are:
- send SMS messages and purchase notifications;
- maintain ICT systems (ticketing systems, call management systems, helpdesk, accounting systems, analytical systems and other IT services), provide internal communications and call handling;
- store, pack and deliver the bulky equipment we sell;
- carry out a "Door 2 Door" service - deliveries with installation, repairs on site if you choose this service;
- provide a dropshipping service;
- store data electronically and ensure secure storage of system data;
- provide a virtual assistant service, an automated customer adviser;
- permanently destroy data media - paper and electronic;
- provide consulting, legal, etc. services to support us in the implementation of individual processes;
- provide marketing services for us to optimise and improve the effectiveness of the marketing activities we target at our customers. These entities help us improve the overall quality of the services we provide, learn about consumer sentiment, profile, provide reports and marketing metrics, including:
- social media, for example Facebook, which support product advertising and advertising campaigns;
- entities that provide services for measuring and researching customer traffic on the website;
- provide an opinion service for users of online shops and platforms that rank retailers, products and prices based on customer ratings;
- provide remote call and appointment booking services;
- perform warranty repairs and replacements when you make a claim and make use of the warranty on the equipment you have purchased;
- are sales platforms. We share with them, your data, if you buy equipment that we offer through them.
We may also transfer your data to entities that may process it as a data controller in connection with offering certain services. In particular, we may transfer your data to:
- courier companies that deliver orders;
- companies in the financial sector that are payment operators, offer hire purchase, leasing, long-term rental - when you pay for a purchase or choose a specific form of financing;
- insurance companies, if you additionally insure the purchased product;
- to debt collection agencies that act on our behalf;
- our partners, with whom we cooperate in the organisation of promotions, competitions and customer special events;
- companies that collect product and shop reviews, where you can share your opinion about the purchase, the product, the seller (e.g. Ceneo, Opineo).
We are obliged to make your data available on the basis of the law to public institutions that apply to us in connection with investigations into possible violations of the law, these are in particular:
- police, prosecution, courts;
- judicial officers;
- tax and customs authorities;
- government agencies and institutions, including EU institutions countering terrorism and organised transnational crime;
- other state institutions, including services that are entitled to obtain personal data.
We ourselves can also apply to public institutions and provide them with data in the event that we detect a potential crime committed at our premises.
We do not sell your personal data, nor do we share it with aggressive marketing companies (such as photovoltaics, instant loans, equipment shows and others), nor do we exchange it with other entities.
We may transfer your personal data both within countries of the European Union and outside the European Economic Area. The transfer of data outside the EEA is permitted insofar as the European Commission determines that this third country, territory or specific sector(s) within this third country or the international organisation concerned ensures an adequate level of protection (Article 45 RODO).
In the absence of such a statement by the Commission, we may transfer data to a country outside the Union or to an international organisation, provided that adequate safeguards (e.g. a standard data protection clause adopted by the Commission or a supervisory authority competent for the protection of personal data) and enforceable rights and effective legal remedies are provided.
Contact details and Data Protection Officer
For all matters relating to privacy and the protection of your personal data, you can contact by emailing iod@systemybofa.pl.
You may also contact in any other way you choose:
- by calling our hotline on
- via the contact form at www.systemybofa.pl
- by mail to the postal address: Trade Tech Sp. z o.o. with its registered office in: ul. Nowowiejska 1/3 lok.9, 00-643 Warsaw, marked as follows: Data Protection Officer
Changes to the Privacy Policy
We may, if necessary, change the provisions of our Policy in accordance with the rules of change, which are set out in the Terms of Sale. We will notify you in advance of any such change. Whenever we update the Privacy Policy, we will post the latest version on our website under the Privacy Policy tab.