Privacy policy

Privacy Policy

General provisions:

This document sets out the privacy rules, including the use of cookies and the processing of personal data, applicable to the websites managed by An Properties Sp. z o.o., including in particular the online shops operated by An Properties Sp. z o.o.


Definitions:

  1. Seller - An Properties Sp. z o.o. with its registered office in Lubin (ul. Kamienna 1J, 59-300 Lubin, Poland), registered under KRS number: 0000988347, NIP (Tax ID): 6922531708, REGON: 522918248
  2. Shop or Online Shop - the Coven online shop available at www.coven.eu.com, operated by the Seller, being a sales platform through which the Seller makes the Shop’s functionalities available, provides services to Users and enables the conclusion of distance sales agreements for Goods, and through which Users may become acquainted with the Goods in the Shop’s range. Through the Shop, the Seller provides appropriate system, ICT and technological tools for the purpose of providing the above services.
  3. Shop Website - the website available at www.coven.eu.com 
  4. User - a natural person, legal person or organisational unit without legal personality using the functionalities of the Shop.
  5. Customer - a User who has concluded a sales agreement with the Seller.
  6. Consumer - a User who is a natural person performing a legal transaction with the Seller that is not directly related to their business or professional activity, in particular concluding a sales agreement through the Shop.
  7. User Account - means a panel individual to each User, activated for the User by the Seller (after the User has registered and thereby concluded an agreement for the provision of the User Account service), in which the data provided by the User when registering the User Account are stored; creating a User Account is not required in order to use the Shop, including to browse the Shop’s range and to place orders.
  8. Price - the gross remuneration (including tax), specified in Polish zloty or in another currency, due to the Seller for the transfer of ownership of the Goods to the Customer in accordance with the Sales Agreement. The Price does not include delivery costs, unless the terms of a Promotion applied by the Shop provide otherwise.
  9. Order - the Customer’s declaration of intent expressing a direct will to conclude a distance Sales Agreement, submitted by means of distance communication, in particular the Online Service, specifying the Goods in respect of which the Customer makes an offer to conclude a Sales Agreement addressed to the Seller, together with the Customer’s data necessary for the possible conclusion and performance of the Sales Agreement. An order for each item of Goods will be treated as a separate offer by the Customer to conclude a Sales Agreement (technical facilitation). 
  10. Goods - movable items in the Shop’s range which may be the subject of a sales agreement between the User and the Seller.
  11. Sales Agreement - an agreement for the sale of Goods concluded between the User and the Seller through the Shop on the terms set out in the Terms and Conditions.
  12. GDPR - 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.
  13. Newsletter - a service provided by the Seller consisting in sending commercial information, in particular concerning the offer of products and services, in the form of messages (e-mails) by electronic mail to the e-mail address provided by the User.

I. Personal data protection

  1. The controller of the personal data (within the meaning of Article 4(7) GDPR) of Users using the functionalities of the Shop is the Seller, i.e. An Properties Sp. z o.o.
  2. The Seller has appointed a Data Protection Officer (DPO), who may be contacted on matters relating to the protection of personal data and the exercise of the related rights. For this purpose, contact is possible by e-mail at contact@coven.eu.com, as well as by traditional post to: An Properties Sp. z o.o., ul. Dąbrowskiego 44, 50-457 Wrocław, Poland (marked “Data Protection Officer (DPO)”).
  3. Users’ personal data may be processed for the following purposes and on the following legal bases:
    1. accepting orders and performing the sales agreement (legal basis for processing: Article 6(1)(b) GDPR);
    2. ongoing communication on matters relating to orders placed, including their confirmation and providing information on their status (legal basis for processing: Article 6(1)(b) GDPR);
    3. enabling the registration and maintenance of a User Account created in the Shop (where the User creates such an account) and providing other functionalities through the Shop, as set out in the Coven Online Shop Terms and Conditions, under the agreement for the provision of electronic services concluded with the User (legal basis for processing: Article 6(1)(b) GDPR);
    4. enabling the use of the functionalities of other forms referred to in the Coven Online Shop Terms and Conditions under the agreement for the provision of electronic services concluded with the User (legal basis for processing: Article 6(1)(b) GDPR) in accordance with the provisions of the Coven Online Shop Terms and Conditions, as well as on the basis of specific rules governing the use of particular forms, insofar as they apply in particular cases in accordance with a decision taken by the Seller (in which case those rules may specify additional purposes and legal bases for the processing of personal data);
    5. handling complaints relating to concluded sales agreements (Article 6(1)(b) GDPR);
    6. handling complaints relating to a concluded agreement for the provision of electronic services – where the User has concluded such an agreement with the Seller on the terms set out in the Coven Online Shop Terms and Conditions (Article 6(1)(b) GDPR);
    7. receiving and handling requests and enquiries addressed to the Seller other than complaints and matters relating to agreements being performed (e.g. using the contact details indicated on the Shop Website), which constitutes the Seller’s legitimate interest (legal basis for processing: Article 6(1)(f) GDPR);
    8. receiving statements of withdrawal from concluded distance sales agreements, in accordance with the provisions of the Coven Online Shop Terms and Conditions and Chapter 4 of the Polish Act of 30 May 2014 on Consumer Rights, which constitutes the Seller’s legitimate interest (legal basis for processing: Article 6(1)(f) GDPR);
    9. examining and pursuing claims and defending against claims, including identifying persons responsible for possible breaches of law, as well as for the purposes of out-of-court complaint handling and claim pursuit procedures, which constitutes the Seller’s legitimate interest (legal basis for processing: Article 6(1)(f) GDPR);
    10. monitoring the manner in which Users use the services provided through the Shop, with regard to compliance with the provisions of the Coven Online Shop Terms and Conditions, as well as developing the Shop’s functionalities and improving the services provided through it, which constitutes the Seller’s legitimate interest (legal basis for processing: Article 6(1)(f) GDPR);
    11. for direct marketing purposes, including profiling, by selecting and displaying available Shop goods taking into account the activity and preferences of particular Users, which constitutes the Seller’s legitimate interest (legal basis for processing: Article 6(1)(f) GDPR);
    12. carrying out statistical analyses, which constitutes the Seller’s legitimate interest (legal basis for processing: Article 6(1)(f) GDPR);
    13. complying with legal requirements under tax and accounting regulations, in particular those set out in the Polish Act of 11 March 2004 on Goods and Services Tax (VAT), the Act of 15 February 1992 on Corporate Income Tax and the Act of 29 September 1994 on Accounting (legal basis for processing: Article 6(1)(c) GDPR);
    14. storing data for archiving purposes and for the purpose of demonstrating the proper fulfilment of the legal obligations incumbent on the Seller, which constitutes its legitimate interest (legal basis for processing: Article 6(1)(f) GDPR);
    15. sending commercial information by electronic means in the form of the Newsletter – where the person concerned has given separate consent to receive commercial information by electronic means, in accordance with Article 398 of the Polish Act of 12 July 2024 – Electronic Communications Law (legal basis for processing: Article 6(1)(a) GDPR);
    16. transferring (sharing) the User’s data to third parties cooperating with the Seller for the purpose of directing online advertising to Users, conducting analytical research, improving the display of advertisements and their personalisation, tailoring content and improving the solutions and services provided by entities cooperating with the Seller, including operators of social media platforms – where the person concerned has given separate consent to such transfer and further use of data by the Seller and the entities cooperating with it; 
    17. storing data in the form of cookies and collecting data from the Shop Website (insofar as such information constitutes personal data) – where the person concerned has given separate consent thereto on the terms set out in the Cookies Policy applicable on the Shop Website (see Section II).
  1. Users’ personal data may be disclosed to the following categories of recipients:
    1. subcontractors providing the Seller with technical support in running, maintaining and developing the Shop, such as: hosting service providers, providers of Shop management software, providers of technical support for the Shop software, providers of software for sending commercial correspondence by electronic means, providers of Customer Service, providers of software used to communicate with Users, including communication carried out by means of dedicated algorithms, providers of cybersecurity tools, and providers of integrated electronic payment platform solutions, with whom the Seller has concluded legally required data processing agreements;
    2. entities supporting the Seller in its marketing (in particular online) and sales activities, including measuring the effectiveness of online advertising campaigns, tailoring advertisements to Users’ preferences and running behavioural (personalised) advertising, such as marketing agencies, remarketing service providers, operators of websites, including social media platforms, and Google;
    3. entities supporting the Seller in complying with applicable laws and in exercising the rights and performing the obligations arising from the Coven Online Shop Terms and Conditions in connection with the provision of services through the Shop, such as law firms and debt collection agencies;
    4. entities to which the transfer of data is necessary to ensure the proper provision of services through the Shop at the request of the particular User – providers of electronic payment services (where such a payment option is chosen) and entities delivering goods to the indicated address (postal, carriage or courier services, freight forwarders), to which the data are made available as independent controllers or with which the Seller has concluded legally required data processing agreements (depending on the status of those entities with regard to the personal data transferred).
  2. Users’ personal data may be transferred by the Seller outside the European Economic Area (EEA) where the Seller uses the services of subcontractors (from among the categories of recipients indicated in point 4 above). In such a case, the Seller guarantees the legally required safeguards for personal data, which will be (as the case may be): i) transfer of data to a subcontractor located in a third country in respect of which an adequacy decision has been issued, in accordance with the requirements of Article 45 GDPR, ii) transfer of data on the basis of a data transfer agreement concluded with the subcontractor based on the Standard Contractual Clauses adopted by Commission Decision of 4 June 2021 (Decision (EU) 2021/914), iii) transfer of data under binding corporate rules applied by the subcontractor, as referred to in Article 47 GDPR. Further information on the safeguards applied by the Seller in connection with the transfer of data outside the EEA may be obtained by contacting the Data Protection Officer appointed by the Seller.
  3. Apart from the cases referred to above, Users’ personal data may be transferred outside the EEA only where a particular User places an order from a country located outside the EEA and expects the ordered goods to be delivered to that country. In such a case, the Seller will transfer the User’s personal data outside the EEA solely for the purpose of the proper performance of the order placed, to the address indicated in the order, in accordance with the User’s request.
  4. The personal data obtained will be stored by the Seller for the period of performance of the concluded Sales Agreements and until they are properly settled, as well as for the period during which the Shop’s services are provided (to Users) for the term of the agreements for the provision of electronic services, and in addition:
    1. until the limitation period for potential claims arising from the agreements indicated above has expired,
    2. for the time necessary to pursue specific claims raised by the Seller or to defend against them (where claims have been raised by the User in connection with the agreements referred to above),
    3. for the time necessary to perform obligations arising from the law, in particular tax and accounting regulations, e.g. obligations relating to the retention of documentation in accordance with the requirements of Article 74 of the Polish Act of 29 September 1994 on Accounting,
    4. for the period necessary for the Seller to demonstrate to public administration authorities, including the personal data protection supervisory authority, the proper fulfilment of the legal obligations incumbent on it,
    5. for archiving purposes, where this concerns the history of correspondence and responses to enquiries (not directly related to concluded agreements) – for a period not exceeding 3 years from obtaining the data,
    6. for direct marketing purposes – for the term of the agreement for the provision of electronic services (Users) and for the period of performance of sales agreements, or until an objection to the processing of data for this purpose is raised,
    7. until consent to the processing of data is withdrawn or the data become outdated (as determined by the Seller), but no longer than 3 years from the date of the User’s last activity relating to the service to which the consent applies – where the data are processed on the basis of consent given by the person concerned.
  5. The Seller ensures that each User may exercise all of their rights under the GDPR, i.e. the right to request access to their personal data, the right to rectification, erasure or restriction of processing, the right to data portability, and the right to object to processing, on the terms and in the cases provided for in the GDPR.
  6. Where personal data are processed by the Seller for the purposes of its legitimate interests (referred to above), each User has the right to object to the processing of data on grounds relating to their particular situation.
  7. Data processed for the purposes of the legitimate interest consisting in the Seller’s direct marketing will be processed only until an objection to this form of processing is raised. The User has the right to object at any time to the processing of their personal data for direct marketing purposes, including profiling.
  8. Where the Seller processes personal data on the basis of consent given by the User, each person has the right to withdraw their consent to the processing of their data at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
  9. The provision of personal data with regard to:
    1. Users who wish to create a User Account in the Shop – in order to register and create a User Account, it is necessary to provide the data indicated in the registration form, i.e. first name, surname, residential address and e-mail address. Failure to provide these data will prevent the creation of a User Account (and consequently the conclusion of an agreement for the provision of electronic services), but the Customer will still be able to order goods through the Shop without registering a User Account;
    2. Users placing orders through the Shop – in order to place an order and enable the Seller to perform it (and thus the sales agreement), it is necessary to provide the following data: first name, surname, residential address (or another delivery address), e-mail address and telephone number. Failure to provide these data will make it impossible to accept the order (and thus to conclude the sales agreement);
    3. Users submitting a statement of withdrawal from a sales agreement – in order to submit a declaration of withdrawal from a distance sales agreement, it is necessary to provide the following data: first name, surname, e-mail address, address (street, building/flat number, postal code, town (post office)), telephone number, order number and bank account number. Failure to provide this information will prevent the effective submission of the declaration of withdrawal from the sales agreement, and failure to indicate a bank account number may prevent the refund of the amount due,
    4. Users submitting complaints in connection with a concluded sales agreement – in order to submit a complaint and enable the Seller to examine it, it is necessary to provide the following data: first name, surname, e-mail address, bank account number, address (street, building/flat number, postal code, town (post office)), telephone number, the requested form of remedy, order number, and information on which goods the complaint concerns and the reason for it. Failure to provide these data will prevent the Seller from examining the complaint,
    5. Users submitting complaints in connection with an agreement for the provision of electronic services concluded with the Seller on the terms set out in the Coven Online Shop Terms and Conditions – in order to submit a complaint and enable the Seller to examine it, it is necessary to provide the e-mail address given by the User when registering the User Account in the Shop or when subscribing to the Newsletter (where the complaint concerns that service); the Seller recommends that the complaint should include in particular the following data: the User’s first name, surname, e-mail address, address (street, building/flat number, postal code, town (post office)) and telephone number. Failure to provide the necessary data may prevent the Seller from examining the complaint,
    6. other cases – is voluntary.
  10. The Seller will not carry out automated processing of Users’ data that would result in decisions producing legal effects concerning them or similarly significantly affecting their situation. Any automated processing of data, including profiling, serves to analyse and predict the individual preferences of Users using the Shop (e.g. personalisation of displayed products and advertising content) and does not result in decisions producing legal effects or similarly significantly affecting the User’s situation within the meaning of Article 22 GDPR.
  11. Every person whose personal data are processed by the Seller has the right to lodge a complaint concerning the processing of their personal data with the supervisory authority, i.e. the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), ul. Jana Pawła II 35, 00-099 Warsaw, Poland.

II. Cookies Policy for users of the websites of An Properties Sp. z o.o.

  1. This cookies policy sets out the rules for the use of small files, called “cookies”, used by the websites managed by An Properties Sp. z o.o.
  2. Cookies are small text files saved and stored on the devices through which the User uses websites. Cookies usually contain the name of the domain from which they originate, their storage period on the User’s end device and an individual, randomly selected number identifying the file. The main purpose of cookies is to make it easier for the User to use websites and to make them more user-friendly, without causing any damage to the User’s computer or other end device.
  3. Cookies are safe for the computers of website Users. In particular, it is not possible for viruses or other unwanted or malicious software to reach users’ computers in this way.
  4. Information collected by means of such files is stored for the purpose of maintaining the User’s session on the website; it may improve the website by producing estimates of website usage statistics, helps to tailor the products offered by An Properties Sp. z o.o. to the individual preferences and actual needs of Users, speeds up the search process and may also enable the display of advertisements, both from websites managed by An Properties Sp. z o.o. and from third-party websites or otherwise, based on an analysis of the User’s browsing habits.
  5. In principle, two types of such files may be stored on the User’s device: first-party cookies (created by the website visited by the User – these cookies primarily enable the website to function properly, including the display of its individual elements; disabling them may restrict or completely prevent the display of the website content) and third-party cookies (created by external websites and supplied by third parties; they are installed on the User’s device and remain there until they are deleted or expire).
  6. Depending on the purpose for which cookies are used, the websites managed by An Properties Sp. z o.o. may allow the following types of cookies to be stored on the User’s device:
    • Necessary
    • Preferences
    • Statistics
    • Marketing
  1. Cookies other than necessary cookies (preferences, statistics, marketing) are stored on and read from the User’s device only after the User has given consent via the cookie banner displayed during the first visit to the Shop Website. The User may change or withdraw consent at any time using the “Cookie settings” link in the Shop footer. Independently of this, the User may manage cookies via the web browser settings. These settings may be changed in particular so as to block the automatic handling of cookies in the web browser settings or to notify the User each time cookies are placed on the User’s device. Detailed information on the options and methods of handling cookies is available in the software (web browser) settings. Below we explain how to change web browser settings regarding the use of cookies:
    1. Edge browser
    2. Mozilla Firefox browser
    3. Chrome browser
    4. Safari browser
    5. Opera browser
  2. The User may delete cookies at any time using the functions available in the web browser they use.
  3. The websites managed by An Properties Sp. z o.o. contain links and references to other websites (managed by other entities). An Properties Sp. z o.o. is not responsible for the privacy rules applicable on those websites.
  4. The Shop uses cookies and similar technologies and processes Users’ personal data (including device and browser identifiers, IP address, and information on activity in the Shop, including products viewed and purchases made) for the purposes of analytics, displaying advertisements and ads personalisation. The legal basis for processing data for these purposes is the User’s consent given via the cookie banner (Article 6(1)(a) GDPR). Third parties may also have access to these data, in particular Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) in connection with the Google Ads, Google Analytics and Google Tag Manager services, Meta Platforms Ireland Limited in connection with Meta advertising services, and TikTok Technology Limited in connection with TikTok advertising services. Information on how Google uses data from sites and apps that use its services is available at: https://business.safety.google/privacy/. Data used for ads personalisation are transferred to Google, Meta and TikTok only after the User has consented to marketing cookies. In the absence of such consent, Google receives only limited signals, without cookies being stored on or read from the User’s device (Google Consent Mode v2).