GDPR package

GDPR package at FAKRO Sp. z o.o.


General information

We value your privacy, and we conduct our daily operations in full compliance with personal data protection regulations. This document explains why we collect personal data, the scope of the data we process, the legal basis for doing so, how long we store it and who may receive it. You will also learn about the rights you have in relation to the processing of your personal data.

This document has been prepared in accordance with the EU General Data Protection Regulation 2016/679 (“GDPR”).

Its purpose is to bring clarity to the way personal data is managed and, above all, to ensure the protection and safeguarding of your personal data.


How you can contact us

For all matters — including those related to personal data — you can contact us via our website, email, telephone, chat, collaboration platforms or traditional mail. Our contact details are as follows:

FAKRO sp. z o.o.

ul. Węgierska 144a

33-300 Nowy Sącz

email: fakro@fakro.pl

telephone: (18) 444 0 444


GDPR principles

When working with your personal data, we follow the following principles:

  • Lawfulness, fairness and transparency. We process personal data in accordance with legal regulations. We clearly and transparently inform you which of your data we collect, process and store.
  • Data minimisation. We process only the data that is genuinely necessary to achieve a specific purpose.
  • Accuracy. We ensure that your data is up to date. From time to time, we take actions to verify and correct it when needed.
  • Purpose limitation and storage limitation. We collect your data only when we have a legitimate purpose and when the purpose cannot be achieved in another way. We store your data only for as long as it is needed to identify you during the fulfilment of that purpose, in accordance with applicable laws.
  • Integrity and confidentiality. We take all necessary measures to secure your personal data and protect it against unauthorised access.
  • Accountability. We are able to demonstrate that we process your personal data in compliance with the law, including the principles of privacy by design and privacy by default.

Data Protection Officer

We have appointed a Data Protection Officer (DPO) whom you can contact with any questions or requests regarding personal data. You can do so in the following ways:

by post, at the following address:

Data Protection Officer - Kinga Nowobilska

ul. Węgierska 144a

33-300 Nowy Sącz

email: iod@fakro.pl

telephone: (18) 444 03 06


How we process personal data

Providing your personal data to us is entirely voluntary. However, certain data is necessary to conclude and perform a contract related to any transaction. If you do not provide this data, we will unfortunately be unable to enter into a contract with you, and as a result, we will not be able to begin cooperation. If legal regulations — for example, tax requirements — oblige us to collect additional essential data, providing such information will also be necessary in order to establish or maintain cooperation with us.


What data we process and on what basis


When we process personal data?

What data we process?

Purpose of processing

Legal basis

Retention period

Business activities

First name, last name, contact details and other information necessary to conduct cooperation with business partners.

We process personal data of individuals, customers, suppliers and other stakeholders in order to carry out business activities.

Art. 6(1)(B)

Art. 6(1)(C) – np. Ustawa o przeciwdziałaniu brudnych pieniędzy

Art. 6(1)(F)

Until the termination of cooperation.

Activities related to concluding and performing a contract / Product-related claims

First name, last name, residential address, email address, telephone number.

Personal data is processed for the purpose of concluding and performing a contract, providing customer service and warranty support, as well as for the establishment, exercise or defence of legal claims.

Art. 6(1)(B) GDPR

Art. 6(1)(C) GDPR

Art. 6(1)(F) GDPR

Until the completion of the service, provision, support, complaint handling or warranty process. In the case of establishing, exercising or defending legal claims — until the last day of the calendar year following a period of three years from the completion of the service.

Registration and purchases in the online store

First name, last name, delivery address, email address, purchase history, contact details, bank account number.

We process personal data for the purpose of fulfilling an order, enabling login to the store through external services, analysing purchase history and handling payments and deliveries.

Art. 6(1)(A) GDPR

Art. 6(1)(B) GDPR

Art. 6(1)(F) GDPR

Until the completion of the service, until an effective objection is submitted, and for the periods specified by applicable law.

Responding to enquiries

Contact, communication, technical and location data processed for the purpose of providing services, performing analysis and integrating with external platforms.

We collect and process personal data in order to handle customer contact (via email, telephone, chat and messaging platforms), fulfil orders, improve service quality and conduct satisfaction surveys. Telephone calls may be recorded for training and evidential purposes.

Art. 6(1)(B) GDPR

Art. 6(1)(F) GDPR

Until the completion of the service or until we provide an answer / fulfil the subject of the enquiry or request. Call recordings are stored for up to 60 days from the date they are created.

Marketing activities

Contact data and technical data (e.g. browsing history, cookie data) collected while using our services and communication channels, as well as those belonging to third-party providers, for the purpose of service provision and interaction analysis.

We use this data for marketing activities, including the creation of personalised offers. Processing for this purpose is based on the customer’s consent, which may be withdrawn at any time.

Art. 6(1)(A) GDPR

Art. 6(1)(F) GDPR

Until consent is withdrawn or an effective objection is submitted.

Newsletter

Email address

Personal data is used to send a newsletter containing information about company news, promotions and events.

Art. 6(1)(A) GDPR

Until consent is withdrawn.

Promotional activities

First name, last name, residential address, email address, telephone number, identity document number, bank account number, National ID (PESEL) number, tax ID.

Personal data is collected for the organisation of promotional activities, registration of participants, delivery of prizes and verification of the winners’ identity.

Art. 6(1)(B) GDPR

Art. 6(1)(F) GDPR

Until the expiry of the period resulting from tax regulations or until an effective objection is submitted.

Participation in photos, videos and campaigns

Image

The image may be processed on the basis of consent or under the provisions of a contract. In certain cases — for example, when the image appears only as an element of a larger photograph — additional consent is not required.

Art. 6(1)(A) GDPR

Art. 6(1)(B) GDPR

Until consent is withdrawn or for the period specified in the contract

Analytical and statistical activities on websites

IP address, cookie-derived data, information about activity on the website.

We monitor activity in the online store to understand customer purchasing preferences. The data is collected, among others, through cookies — their processing requires the customer’s consent.

Art. 6(1)(A) GDPR

Art. 6(1)(F) GDPR

Until consent is withdrawn or an effective objection is submitted.

Digital platforms and mobile apps

Personal data collected on digital platforms and mobile apps.

Personal data is collected through our platforms and apps to improve customer communication and to support the development of our products and services.

Art. 6(1)(B) GDPR

Art. 6(1)(F) GDPR

Personal data is processed for the duration of the contract and, based on legitimate interest, until the expiry of the limitation period or until an effective objection is submitted.

Social media accounts/profiles

First name, last name, username, profile picture, other images containing likeness, statistical data.

We process personal data through our social media accounts for the purposes of communication, promotion, activity analysis and event organisation. Processing occurs, among others, when you subscribe, leave a comment or complete a form. In certain cases, we act as joint controllers of these platforms.

Art. 6(1)(F) GDPR

Until the subscription is withdrawn or for as long as the social media accounts remain active.

Recruitment

First name and last name, date of birth, contact details, education, professional qualifications, employment history.

We require personal data to conduct the recruitment process and, if applicable, to conclude an employment contract, a B2B contract, or to accept a candidate for an internship or traineeship. If you provide consent, your personal data may also be processed for the purposes of future recruitment processes.

Art. 6(1)(A) GDPR

Art. 6(1)(B) GDPR

Art. 6(1)(F) GDPR

Until the expiry of employee-related claims or until consent is withdrawn (if you have provided consent for future recruitment).

Whistleblower protection

First name, last name, email address, nature of the relationship with the company and any other categories of data that may be included in the report to describe the irregularity accurately.

Personal data is processed as part of the whistleblower protection procedure exclusively by authorised persons and solely for the purpose of handling reports of violations of law or internal regulations.

Art. 6(1)(C)

Art. 6(1)(F)

Until the expiry of claims arising from applicable legal provisions, including the Civil Code, or until the expiry of the limitation period for criminal offences under the Criminal Code.

Video monitoring

Image

Image (likeness) is processed as part of video monitoring for the purposes of ensuring safety, protecting property, controlling production processes and safeguarding confidential information.

Art. 6(1)(B)

Art. 6(1)(C)

Art. 6(1)(F)

Recordings are stored for a maximum of 3 months from the date they are made. If recordings constitute evidence in proceedings conducted under applicable law, the retention period may be extended until the final conclusion of the proceedings.

Training activities

First name, last name, telephone number, email address, company/institution name, company registered address, image (likeness).

Educational activities related to our product offering.

Art. 6(1)(A) GDPR

Art. 6(1)(B) GDPR

Art. 6(1)(F) GDPR


5 years or for the duration of cooperation including the applicable claims period.

Use of artificial intelligence

First name and last name, email address, photos or video recordings, information from platform accounts, answers provided during the recruitment process.

Personal data may be processed using AI technologies to streamline processes and improve services, including cooperation with external technology providers.

Art. 6(1)(F) GDPR

Personal data is stored and processed for the period necessary to fulfil the stated purposes, unless the user submits an effective written objection.

When we process personal data?

What data we process?

Purpose of processing

Legal basis

Retention period

Business activities

First name, last name, contact details and other information necessary to conduct cooperation with business partners.

We process personal data of individuals, customers, suppliers and other stakeholders in order to carry out business activities.

Art. 6(1)(B)

Art. 6(1)(C) – np. Ustawa o przeciwdziałaniu brudnych pieniędzy

Art. 6(1)(F)

Until the termination of cooperation.

When we process personal data?

What data we process?

Purpose of processing

Legal basis

Retention period

Activities related to concluding and performing a contract / Product-related claims

First name, last name, residential address, email address, telephone number.

Personal data is processed for the purpose of concluding and performing a contract, providing customer service and warranty support, as well as for the establishment, exercise or defence of legal claims.

Art. 6(1)(B) GDPR

Art. 6(1)(C) GDPR

Art. 6(1)(F) GDPR

Until the completion of the service, provision, support, complaint handling or warranty process. In the case of establishing, exercising or defending legal claims — until the last day of the calendar year following a period of three years from the completion of the service.

When we process personal data?

What data we process?

Purpose of processing

Legal basis

Retention period

Registration and purchases in the online store

First name, last name, delivery address, email address, purchase history, contact details, bank account number.

We process personal data for the purpose of fulfilling an order, enabling login to the store through external services, analysing purchase history and handling payments and deliveries.

Art. 6(1)(A) GDPR

Art. 6(1)(B) GDPR

Art. 6(1)(F) GDPR

Until the completion of the service, until an effective objection is submitted, and for the periods specified by applicable law.

When we process personal data?

What data we process?

Purpose of processing

Legal basis

Retention period

Responding to enquiries

Contact, communication, technical and location data processed for the purpose of providing services, performing analysis and integrating with external platforms.

We collect and process personal data in order to handle customer contact (via email, telephone, chat and messaging platforms), fulfil orders, improve service quality and conduct satisfaction surveys. Telephone calls may be recorded for training and evidential purposes.

Art. 6(1)(B) GDPR

Art. 6(1)(F) GDPR

Until the completion of the service or until we provide an answer / fulfil the subject of the enquiry or request. Call recordings are stored for up to 60 days from the date they are created.

When we process personal data?

What data we process?

Purpose of processing

Legal basis

Retention period

Marketing activities

Contact data and technical data (e.g. browsing history, cookie data) collected while using our services and communication channels, as well as those belonging to third-party providers, for the purpose of service provision and interaction analysis.

We use this data for marketing activities, including the creation of personalised offers. Processing for this purpose is based on the customer’s consent, which may be withdrawn at any time.

Art. 6(1)(A) GDPR

Art. 6(1)(F) GDPR

Until consent is withdrawn or an effective objection is submitted.

When we process personal data?

What data we process?

Purpose of processing

Legal basis

Retention period

Newsletter

Email address

Personal data is used to send a newsletter containing information about company news, promotions and events.

Art. 6(1)(A) GDPR

Until consent is withdrawn.

When we process personal data?

What data we process?

Purpose of processing

Legal basis

Retention period

Promotional activities

First name, last name, residential address, email address, telephone number, identity document number, bank account number, National ID (PESEL) number, tax ID.

Personal data is collected for the organisation of promotional activities, registration of participants, delivery of prizes and verification of the winners’ identity.

Art. 6(1)(B) GDPR

Art. 6(1)(F) GDPR

Until the expiry of the period resulting from tax regulations or until an effective objection is submitted.

When we process personal data?

What data we process?

Purpose of processing

Legal basis

Retention period

Participation in photos, videos and campaigns

Image

The image may be processed on the basis of consent or under the provisions of a contract. In certain cases — for example, when the image appears only as an element of a larger photograph — additional consent is not required.

Art. 6(1)(A) GDPR

Art. 6(1)(B) GDPR

Until consent is withdrawn or for the period specified in the contract

When we process personal data?

What data we process?

Purpose of processing

Legal basis

Retention period

Analytical and statistical activities on websites

IP address, cookie-derived data, information about activity on the website.

We monitor activity in the online store to understand customer purchasing preferences. The data is collected, among others, through cookies — their processing requires the customer’s consent.

Art. 6(1)(A) GDPR

Art. 6(1)(F) GDPR

Until consent is withdrawn or an effective objection is submitted.

When we process personal data?

What data we process?

Purpose of processing

Legal basis

Retention period

Digital platforms and mobile apps

Personal data collected on digital platforms and mobile apps.

Personal data is collected through our platforms and apps to improve customer communication and to support the development of our products and services.

Art. 6(1)(B) GDPR

Art. 6(1)(F) GDPR

Personal data is processed for the duration of the contract and, based on legitimate interest, until the expiry of the limitation period or until an effective objection is submitted.

When we process personal data?

What data we process?

Purpose of processing

Legal basis

Retention period

Social media accounts/profiles

First name, last name, username, profile picture, other images containing likeness, statistical data.

We process personal data through our social media accounts for the purposes of communication, promotion, activity analysis and event organisation. Processing occurs, among others, when you subscribe, leave a comment or complete a form. In certain cases, we act as joint controllers of these platforms.

Art. 6(1)(F) GDPR

Until the subscription is withdrawn or for as long as the social media accounts remain active.

When we process personal data?

What data we process?

Purpose of processing

Legal basis

Retention period

Recruitment

First name and last name, date of birth, contact details, education, professional qualifications, employment history.

We require personal data to conduct the recruitment process and, if applicable, to conclude an employment contract, a B2B contract, or to accept a candidate for an internship or traineeship. If you provide consent, your personal data may also be processed for the purposes of future recruitment processes.

Art. 6(1)(A) GDPR

Art. 6(1)(B) GDPR

Art. 6(1)(F) GDPR

Until the expiry of employee-related claims or until consent is withdrawn (if you have provided consent for future recruitment).

When we process personal data?

What data we process?

Purpose of processing

Legal basis

Retention period

Whistleblower protection

First name, last name, email address, nature of the relationship with the company and any other categories of data that may be included in the report to describe the irregularity accurately.

Personal data is processed as part of the whistleblower protection procedure exclusively by authorised persons and solely for the purpose of handling reports of violations of law or internal regulations.

Art. 6(1)(C)

Art. 6(1)(F)

Until the expiry of claims arising from applicable legal provisions, including the Civil Code, or until the expiry of the limitation period for criminal offences under the Criminal Code.

When we process personal data?

What data we process?

Purpose of processing

Legal basis

Retention period

Video monitoring

Image

Image (likeness) is processed as part of video monitoring for the purposes of ensuring safety, protecting property, controlling production processes and safeguarding confidential information.

Art. 6(1)(B)

Art. 6(1)(C)

Art. 6(1)(F)

Recordings are stored for a maximum of 3 months from the date they are made. If recordings constitute evidence in proceedings conducted under applicable law, the retention period may be extended until the final conclusion of the proceedings.

When we process personal data?

What data we process?

Purpose of processing

Legal basis

Retention period

Training activities

First name, last name, telephone number, email address, company/institution name, company registered address, image (likeness).

Educational activities related to our product offering.

Art. 6(1)(A) GDPR

Art. 6(1)(B) GDPR

Art. 6(1)(F) GDPR


5 years or for the duration of cooperation including the applicable claims period.

When we process personal data?

What data we process?

Purpose of processing

Legal basis

Retention period

Use of artificial intelligence

First name and last name, email address, photos or video recordings, information from platform accounts, answers provided during the recruitment process.

Personal data may be processed using AI technologies to streamline processes and improve services, including cooperation with external technology providers.

Art. 6(1)(F) GDPR

Personal data is stored and processed for the period necessary to fulfil the stated purposes, unless the user submits an effective written objection.


We may process your data when:

  1. You have given consent for marketing of products or services, for telephone contact with us (helpline) or for the use of your image.
  2. We engage in joint activities aimed at establishing or carrying out our cooperation, for example:
  • responding to enquiries
  • preparing quotations
  • handling service requests
  • processing complaints
  • conducting online sales
  • delivering training activities
  1. We fulfil a legal obligation in this way: on this basis, we process personal data in order to comply with the duties imposed on us by applicable laws, such as the Payment Services Act, the Tax Ordinance, the Accounting Act, the Copyright and Related Rights Act, and the Act on the Provision of Services by Electronic Means.
  2. Processing may also be required based on our (as the controller’s) legitimate interest, for example:
  • conducting direct marketing of our products or services — their descriptions are available on our website
  • conducting customer satisfaction surveys
  • analysing data to improve products and services
  • monitoring logs, IP addresses and detecting attempts of unauthorised access to systems
  • preparing statistics and reports
  • archiving data
  • pursuing claims

Where we obtain data from, for example:

  • directly from customers
  • from customer representatives, such as payment recipients
  • from other controllers, such as the Credit Information Bureau
  • from publicly available databases, such as the National Court Register or the Central Registration and Information on Business

What rights do you have?

You have the following rights related to the processing of your personal data:

  • You have the right to know which of your personal data is being processed, for what purpose, by whom, and you may request a copy of this data.
  • You may request that inaccurate information be corrected or that incomplete data be completed.
  • You may request that we delete your personal data in specific circumstances.
  • This allows you to temporarily limit how we use your personal data when certain conditions apply.
  • You may receive a copy of your personal data from us or request that it be transferred to another entity.
  • If you believe your personal data is being processed unlawfully, you may file a complaint with the President of the Personal Data Protection Office (address: ul. Stanisława Moniuszki 1A, 00-014 Warszawa).
  • You may withdraw your consent at any time without providing a reason.
  • You may at any time request that we stop processing your personal data when the processing is based on our legitimate interest or for marketing purposes.

We exercise these rights after successfully verifying the identity of the person submitting the request.

A request may be submitted by telephone, email or in person at our registered office, as well as by post. You can also send your request directly to our Data Protection Officer. We will provide a written response without undue delay.


Who we may share your data with

The personal data we collect may be shared with other companies within the FAKRO Group and with companies cooperating with us — our business partners — so that we can assist you in resolving your issue, preparing an offer or organising the provision of a service.

In accordance with the law, we may also share your data with other entities in order to fulfil statutory obligations or to conclude and perform a contract.


We may share your data in particular with:

1. Our employees and collaborators who must have access to the data in order to fulfil our obligations.

2. Other companies within the FAKRO Group with whom we have concluded a joint-controllership agreement or data processing agreements, ensuring an appropriate level of protection when personal data is processed by those companies.

3. Entities processing data on our behalf, participating in the performance of our activities, including:

  • our agents, advertising agencies and other entities involved in the sale of our services or the organisation of marketing campaigns
  • entities that operate our ICT systems or provide ICT tools to us
  • subcontractors supporting us in performing the contract between you and us, e.g., in handling correspondence or customer service
  • entities providing advisory, consulting, audit, legal, tax or accounting services

4. Other data controllers processing data in their own name, such as:

  • our agents, advertising agencies and entities cooperating in the organisation of marketing campaigns or customer service — for the purpose of settling remuneration due to them
  • postal or courier service providers
  • entities purchasing receivables — in the event of non-payment of invoices issued by us
  • payment service providers (banks, payment institutions) — for the purpose of processing refunds for you or enabling the operation of Direct Debit services
  • entities cooperating with us in accounting, tax or legal matters — to the extent that they become data controllers
  • public authorities, such as courts, prosecutors, tax authorities

Do we transfer your data to third countries?

Your personal data may be transferred to so-called “third countries”, meaning countries outside the European Economic Area.

In such cases, to ensure the security of your personal data, we make sure that the transfer to a given third country is safe. This is done through mechanisms such as: a European Commission adequacy decision confirming an adequate level of data protection in that country; the use of Standard Contractual Clauses approved by the European Commission; Binding Corporate Rules; codes of conduct; certification mechanisms; or standard data protection clauses adopted by the supervisory authority.


Automated decision-making, including profiling

Based on your consent, we may use your data for profiling. However, decisions will not be made in an automated manner and will not produce any legal effects concerning you.

Profiling of personal data means processing your data (including automated processing) in order to evaluate certain information about you — in particular to analyse or predict your personal preferences and interests.


Procedures for handling personal data breaches

A personal data breach occurs when personal data is accidentally or unlawfully destroyed, lost, altered, disclosed or made available to unauthorised persons.

In the event a personal data breach is identified, we take the following steps:

1. The data subject:

  • We inform the data subject if the breach may result in a high risk to their rights or freedoms.
  • We provide this information without undue delay. If direct contact is significantly difficult, we publish a public communication.

2. Supervisory authority (President of the Personal Data Protection Office)

  • We report the breach to the supervisory authority if it is likely to result in a risk to the rights or freedoms of natural persons (a risk higher than low).
  • The notification is submitted without undue delay and, where feasible, no later than 72 hours after becoming aware of the breach.

Changes to the Privacy Policy of FAKRO Sp. z o.o.

Due to ongoing changes in the functioning of our company and regularly evolving legal regulations, we may introduce periodic updates to this document. The latest version of the Data Protection Policy will always be available on our website.

Date of GDPR implementation: 25.05.2018

Date of last update to this document: 15.01.2026