Privacy Policy

PRIVACY POLICY

  1. General provisions

    1. This Privacy Policy defines the rules of processing and protection of personal data of the Customers of the Site and the Store available at the following address: www.tryumf.com
    2. Terms not defined in this Privacy Policy have the meaning given to them in the Site’s Terms and Conditions and the Terms and Conditions of the Store.
    3. Personal data means information about an identified or identifiable natural person to whom the data pertain, i.e. one who can be directly or indirectly identified, in particular on the basis of an identifier (feature) such as: first and family name, identification number, location data, internet identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the natural person.
    4. Processing means any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automatic means, such as collection, recording, organization, ordering, storage, adaptation or alteration, retrieval, viewing, use, disclosure, making available, alignment or combination, restriction, erasure or destruction.
    5. Customers' personal data are processed in accordance with the applicable regulations, in particular the Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and the repealing of Directive 95/46/EC (General Data Protection Regulation, hereinafter referred to as the “General Data Protection Regulation”): “GDPR”) and the Act of May 10, 2018 on personal data protection.
    6. In order to ensure the security of Customers' personal data, the controller applies appropriate technical and organizational measures in the area of personal data processing security.

  2. Data controller

    1. Subject to clause 2.2., the controller of Customers' personal data is TRYUMF Sp. z o.o. with its registered office in Stalowa Wola, ul. Władysława Grabskiego 8, 37-450 Stalowa Wola, entered in the Register of Entrepreneurs kept by the District Court in Rzeszów, XII Commercial Department under the KRS number 0000156311, REGON number: 831351006, Vat number: 8651006315 (hereinafter „Tryumf”). Contact with Tryumf is possible in writing to the address indicated in the first sentence or through the daneosobowe@tryumf.com e-mail address.
    2. In case of personal data of the Customer processed in connection with the Sales Contract, where the Partner is a party (as a Seller within the meaning of the Terms and Conditions of the Store), the controller of the Customer's personal data is the Partner. The list of partners is available in the Contact tab. The contact details of the Partner selected by the Customer when placing the Order are also specified in the Order Confirmation.
    3. Tryumf is the entity processing personal data on behalf of the Partner in the scope preceding the conclusion of the Sales Contract by the Customer with the Partner (as the Seller) through the Store.

  3. Purposes and legal basis for processing personal data of Customers

    1. Customers' personal data are or may be processed:
      1. in order to conclude and perform the Sales Contract concluded through the Store, processing by Tryumf or a Partner is in this case necessary to conclude and perform the contract to which the Customer is a party, or to take action at the request of the Customer, before the conclusion of the contract (Article 6.1.b of the GDPR);
      2. in order to register and maintain an Account at the Site – data processing by Tryumf is in this case necessary for the performance of a contract for the provision of services by electronic means, to which the Customer is a party, or to take action at the request of the Customer, prior to the conclusion of the agreement (Article 6.1.b of the GDPR);
      3. in order to provide the Newsletter – data processing by Tryumf takes place in this case on the basis of the Customer's consent (Article 6.1.a GDPR);
      4. in order to settle a matter described by the Customer in the electronic form available at the Site and by means of the chat option at the Site with the Customer's account manager: data processing by Tryumf is in this case necessary to conclude and perform the contract for the provision of services through electronic means (Article 6(1)(b) GDPR), and also takes place on the basis of the legitimate interest of Tryumf (Article 6(1)(f) GDPR) consisting in supporting sales;
      5. in order to provide electronic services pertaining to providing customers with the possibility of viewing, reproducing and reading of information and materials made available as part of the Site: data processing by Tryumf is in this case necessary for the performance of the contract, to which the customer is a party (Article 6.1.b of GDPR);
      6. in order to use the Configurator at the Site for designing the Goods: data processing by Tryumf is in this case necessary for the performance of the contract to which the Customer is a party (Article 6 (1)(b) of GDPR);
      7. for the purposes of exercising the legitimate interest of Tryumf, connected with operating the Site and the Shop, including analysis of the Customer's use of the www.tryumf.com website, ensuring the safety and reliability of services provided within the Site and the Store (Article 6(1)(f) GDPR);
      8. w celu badania satysfakcji Klientów z usług i Towarów (np. poprzez ankiety przesyłane Klientom pocztą elektroniczną) – przetwarzanie danych przez Tryumf lub Partnera następuje w oparciu o uzasadniony interes Tryumf lub Partnera (art. 6 ust. 1 lit. f RODO);
      9. in order to pursue the legitimate interests of Tryumf or a Partner, which may include, but are not limited to, the identification, pursuing and defense of claims, prevention and investigation of criminal offenses, business management and further business development, including risk management (Article 6(1)(f) of the GDPR);
      10. in order to measure the satisfaction of customers with services and Goods (e.g. through questionnaires sent to customers by e-mail), data processing by Tryumf or the Partner is based on the legitimate interest of Tryumf or the Partner (Art. 6.1. GDPR);
      11. for the purposes of direct marketing of Tryumf, including the selection of Goods and services for the needs of customers (including profiling) based on cookies and other similar technologies referred to in item 10. Data processing by Tryumf takes place in this case on the basis of the legitimate interest of Tryumf (Article 6(1)(f) GDPR);
      12. for Tryumf’s marketing purposes, resulting from the consent given by the Customer (art. 6 sec. 1(a) of GDPR);
      13. in order to ensure compliance with the legal obligations imposed on Tryumf or the Partner (in particular those resulting from the provisions of the Accounting Act and tax regulations), when processing is necessary to fulfill the legal obligation incumbent on the controller (Article 6(1)(c) of the GDPR).
    2. Providing personal data at the Site and Store is voluntary, but it may be necessary for the delivery of one or more services and purposes of personal data processing, specified in item 3.1. above, which Triumph or Partner (as a Seller) will not be able to deliver in the event of failure to provide personal data.
    3. The Customer's personal data collected through the Customer's direct contact with Tryumf's consultant, including through the helpline or as part of contact with the Customer's account manager, are used exclusively for the purpose of contact with the Customer and providing information and advice to the Customer.

  4. Scope of processing of the Customer’s personal data

    1. The scope of the Customer’s personal data processed by Tryumf includes:
      1. the customer’s data provided during the Registration: first and family name, address of residence, delivery address, e-mail address, telephone number, and in the case of Customers who are not Consumers, additionally company name and VAT number;
      2. Customer’s data, made available to Tryumf via Facebook, if the Customer has chosen the Facebook Registration option (see section 9.4.);
      3. Customer’s data obtained by Tryumf in connection with the use of cookies and other similar technologies (see item 10);
      4. dthe Customer’s data concerning the Order placed by the Customer in the Store, including the Customer's data contained in files and designs made available by the Customer;
      5. other data of the Customer, voluntarily provided by the Customer using electronic forms available at the Site or any other form of contact with Tryumf’s consultant.
    2. The scope of the Customer's personal data processed by the Partner includes the data made available by the Customer, necessary for the conclusion and performance of the Sales Contract with the selected Partner, i.e., the following data:
      1. first and family name, address, delivery address, e-mail address, telephone number, and in the case of Customers who are not Consumers, additionally the company name and the VAT number;
      2. other data provided by the Customer as part of the Order placed with the Store.
    3. Due to the fact that the services offered within the Service and the Shop are addressed to adults, the controller does not knowingly process personal data of children using the services offered within the Site and the Store.

  5. Rights and obligations of the Customer

    1. If the processing of personal data takes place on the basis of the Customer's consent, such consent is voluntary and may be revoked at any time, without affecting the lawfulness of the processing which took place before the withdrawal of consent. The statement on withdrawal of consent should be submitted by e-mail to Tryumf’s e-mail address, indicated in item 5.5.
    2. At any time, the customer has the right to access and amendments of their data.
    3. The customer is also vested with the following rights:
      1. to delete their personal data;
      2. dto limit the processing of their personal data;
      3. have access to the content of their personal data as well as correction;
      4. to receive copies of their data or to transfer them, but this right must not adversely affect the rights and freedoms of others (including trade secrets or intellectual property rights) and will be exercised to the extent technically possible;
      5. to object to the processing of their personal data where the processing is based on the legitimate interests of the controller or of a third party.
    4. The controller shall exercise the rights of the Customer, subject to exceptions specified in the provisions of the GDPR.
    5. A registered customer may also correct or update his or her personal data concerning the Account on his/her own. In order to do so, they should log in to www.tryumf.com, go to the “Account details” tab and make appropriate changes.
    6. In order to exercise the rights specified in items 5.1 and 5.2, an e-mail should be sent to the controller's address, i.e:
      1. to the e-mail address of the Partner selected by the Customer, indicated in the Order confirmation, in the event of personal data of the Customer processed in connection with the Sales Contract, where the Partner is a party;
      2. to the e-mail address of Tryumf daneosobowe@tryumf.com - in the event of personal data of the Customer processed in connection with the Sales Contract, to which Tryumf is a party, as well as in other cases concerning the processing of personal data of the Customer, in connection with the use of the Site.
    7. The Customer is entitled to lodge a complaint to the supervisory body – the President of the Office for Personal Data Protection, if they think that the processing of data concerning them violates the provisions of the GDPR.
    8. Any events that have or may have an impact on the security of personal data at the Site and the Store (including those related to suspicion of sharing files containing viruses and other files of a similar nature or other than files with destructive mechanisms), the Customer is obliged to immediately report to Tryumf at the daneosobowe@tryumf.com address.

  6. Period of processing of the Customer’s personal data

    1. The controller processes the Customer's personal data in the manner and for the period necessary to achieve the purposes for which the data was collected.
    2. In the event of data processing:
      1. for the purpose of concluding and performing the contract (including the Sales Contract), the Customer's data will be processed for the duration and performance of the contract;
      2. on the basis of the Customer's consent, the Customer’s data will be processed until the withdrawal of the consent;
      3. in order to ensure compliance with the legal obligations imposed on Tryumf or Partners, the Customer's data will be processed for the period required by law;
      4. for the purposes of Tryumf’s direct marketing, including the selection of Goods and services to the needs of customers (profiling), the Customer's data will be processed until the customer objects;
      5. for the purposes of other legitimate interests of the controller, the data will be processed until such time as the objection raised by the Customer has been accepted or the statute of limitations period has expired.
    3. After the expiry of the processing period, the data is deleted or anonymized.

  7. Entities to which personal data of the Customers are made available

    1. The controller provides personal data of the Customers, if there exists a legal basis for it, in particular when it is necessary to perform the services provided to the Customers.
    2. The Customers' personal data may also be made available at the request of public authorities or other entities entitled to such access on the basis of legal regulations, in particular when it is necessary to ensure the security of Tryumf systems.
    3. The recipients of personal data of the Customers may be in particular:
      1. 3.1 the entities whose services are used by the controller in order to deliver the Goods and services to the Customers, in particular:
      2. 3.2 to the courier on receipt of goods (cash on delivery).
        1. entities providing data communications systems or services to the controller;
        2. entrepreneurs providing delivery and maintenance services of the software used to operate the Service and the Store;
        3. operators of payment systems;
        4. entities providing postal and courier services;
        5. law firms, consulting firms with which the controller cooperates;
      3. 3.3 trusted marketing partners of Tryumf:
        1. Google LLC in connection with the use of Google Analytics;
        2. Edrone Sp. z o.o. in connection with the use of edrone CRM;
        3. Facebook in connection with the use of Pixel;
        4. Freshmail

  8. Transmission of data outside the EEA

    1. The controller shall transfer personal data outside the European Economic Area (EEA) only when necessary and with an adequate level of protection, in particular by:
      1. cooperation with processors of personal data in countries for which a decision of the European Commission has been issued;
      2. the use of standard contractual clauses issued by the European Commission;
      3. the application of binding corporate rules approved by the competent supervisory authority;
      4. when transferring data to the US, cooperation with entities participating in the Privacy Shield scheme as approved by Commission Implementing Decision (EU) 2016/1250 of 12 July 2016 on the adequacy of the protection provided by the EU-US Privacy Shield (the list of US entities participating in this scheme is available at the following address: https://www.privacyshield.gov/list).
    2. Where applicable, the controller shall always indicate its intention to transfer personal data outside the EEA at the stage of collection. At the Customer's request, the controller shall provide the Customer with a copy of his or her data which will be transferred outside the EEA.

  9. Social networks

    1. The site contains links to external social networking sites: Facebook, YouTube, Instagram, LinkedIn. Tryumf is not responsible for their content and is not responsible for the consequences of using such portals.
    2. Transfer of the Customer's personal data to the portals referred to in clause 9.1. and processing of the Customer's personal data by the controllers of these portals may take place with the Customer's consent only after their activation, i.e. clicking a specific link. Then the so-called plug-in of the specific social networking sites is activated, and then the Customer's browser will connect the Customer directly to the portal.
    3. The rules of personal data processing by social networking sites can be found in the section on personal data protection of the portal in question. The social networking site is responsible for the processing of data that begins when the Customer clicks on a particular link.
    4. A customer wishing to use the service of access to the Account and the related services has the opportunity to Register and log-on using their Facebook account. Facebook can then automatically forward the following personal data to Tryumf:
      1. the numeric identifier of the social networking site (ID)
      2. First and family name
      3. gender
      4. profile photo
      5. age
      6. other public information.
    5. In the case referred to in clause 9.4, no additional registration is necessary in order to open a Customer Account with the Site. The user account on Facebook will be linked to the Customer Account, which will enable authentication and logging into the Customer Account through the Customer's Facebook account. Thanks to this, the Customer does not have to remember the Login and Password to the Account.
    6. The legal basis for the processing of the Customer's personal data in connection with the use of the optional Registration and logging in through Facebook is the Customer's consent (Article 6(1)(a) of the GDPR).
    7. In addition, Tryumf uses selected business tools offered by Facebook in the form of Pixel. Detailed information on how these tools work can be found at www.facebook.com. The Customer was also informed separately by Facebook about the operation of Pixel. Thanks to these tools, if the customer is also a Facebook user, Facebook can display personalized content. For more information on settings and preferences regarding the content displayed to the customer on Facebook, please visit https://www.facebook.com/about/ads

  10. Cookies and other similar technologies

    1. In accordance with the practice of most websites, when using the Site and the Store, the Customer's personal data may be collected automatically in the system logs of the Site, through cookies, the Google Analytics system and the edrone CMR system.
    2. Cookies are files stored on the Customer's terminal equipment, used to identify Customers and provide the controller with statistical information about Customer traffic, Customer activity and the manner of using the Site and Store. They allow, among other things, to adjust the content and services at the Site and Store to the preferences of Customers.
    3. The Site and the Store use session cookies, which are deleted after closing the browser window, as well as persistent cookies, stored for a specified period of time (specified in the parameters of cookie files or until they are deleted by the Customer) in the terminal devices through which the Customer uses the Site or the Store.
    4. Tryumf uses the following types of cookies:
      1. cookies necessary for the use of services, e.g. used for services requiring authentication;
      2. cookies facilitating logging into the Account via social media;
      3. cookies ensuring security;
      4. cookies collecting data on the use of the services;
      5. cookies enabling storage of the settings selected by the Customer and personalization of the customer interface;
      6. cookies used to provide customers with content more suited to their preferences and interests.
    5. Tryumf processes, in accordance with the law, data concerning the number (including IP) and type of end device of the Customer, as well as the time of the Customer's connection with the Site and the Store and other operational data concerning the Customer's activity at the Site and the Store, including their preferences. The data described above is processed for technical purposes in order to adapt the Site and Store to the needs of the Customers and to collect general statistical information concerning the operation of the Site and Store, as well as for the purposes of personalization of content provided to the Customer.
    6. The Customer may independently and at any time change the settings concerning cookies, specifying the conditions of their storage and access through cookies to the Customer's terminal device, using the settings of the Internet browser. These settings may be changed, in particular, in such a way as to block the automatic handling of cookies in the settings of the Internet browser or to notify the Customer every time cookies are placed on the Customer's final device.
    7. The Customer can delete cookies at any time using the available functions in the web browser they are using. Tryumf reserves, however, that this may result in the limitation of some functionalities available at the Site and Store.
    8. Tryumf also uses Google Analytics, i.e. a web analytics system providing insight into the traffic of personal data and location data of users, used to create statistics and reports on the operation of the Site, as well as to personalize the content of displayed advertisements. Detailed rules of data processing by Google LLC and rules of opting out of cookies used by Google LCC are available at: www.google.com/policies/privacy/partners/ .
    9. The Customer's activity at the Site, including their personal data, is registered in system logs (log files used to store chronological records containing information about events and activities concerning the IT system used for the provision of services by Tryumf). The information collected in the logs is processed primarily for the purposes related to the provision of services. Tryumf also processes them for technical and administrative purposes, to ensure the security and management of the IT system, as well as for analytical and statistical purposes – in this respect the legal basis for processing is the legitimate interest of the controller (Article 6(1)(f) of the GDPR).
    10. Tryumf also uses the edrone CRM system, used to collect and process the Customer’s data, in particular their activities on the basis of cookies, local storage and other technologies, in order to personalize the content made available to the customer.

  11. Processing of personal data of third parties

    1. Third parties are natural persons whose personal data is placed by the Customer at the Site or as part of placing an Order in the Store.
    2. If the Customer places any personal data of third parties at the Site or as part of placing an Order in the Store, they can only do so if he does not violate the applicable law and the personal rights of these persons.
    3. Tryumf or Partner (as the Seller) may process personal data of third parties entrusted to them by the Customer, if the Customer confirms that he is entitled to transfer personal data of a third party.
    4. In cases where the Customer places data of third parties at the Site or as part of placing an Order in the Store, as part of activities other than purely personal or domestic, the Customer acts as the controller of such data within the meaning of the GDPR regulations.
    5. In the case referred to in item 11.4 above, the Customer concludes an agreement with Tryumf or a Partner (as the Seller) to entrust data processing to Third Parties in accordance with the principles specified in items 11.6. – 11.11. below.
    6. Data of third parties, entrusted by the Customer to the Seller (Tryumf or Partner), in connection with the Order, will be processed by the Seller in order to properly carry out the Sales Contract concluded with the Customer.
    7. Data of third parties, entrusted by the Customer in connection with the use of the Site, will be processed by Tryumf in order to properly implement the contract concluded with the Customer for the provision of services by electronic means.
    8. The scope of the entrusted data includes all personal data of third parties entrusted in connection with the Customer's use of the Site or in connection with the submitted Order, in particular first and family name, address, gender, image, date of birth or age.
    9. The Customer agrees to further outsourcing the processing of data to third parties (the so-called sub-contracting), in order to perform the contract concluded with the Customer.
    10. Personal data of third parties entrusted by the Customer will be processed respectively by Tryumf or Partner (as the Seller) in accordance with Article 28 of the GDPR.
    11. Personal data of third parties may also be processed by Tryumf or the Partner (as the Seller), for the purpose of possible determination and enforcement of claims or defense against them. The legal basis of the processing is the legitimate interest of Tryumf or the Partner as the controller (Article 6(1)(f) of the GDPR), consisting in the protection of their rights.
    12. If Tryumf determines that personal data of third parties is being processed by Tryumf in violation of the provisions of the GDPR, applicable law or personal rights of third parties, Tryumf will take steps to delete such data as soon as possible.

  12. Final provisions

    1. This Privacy Policy is reviewed on an ongoing basis and, if necessary, updated to reflect any changes in the way personal data is processed. Tryumph can also make changes in accordance with the requirements of applicable regulations or legal requirements. Information about the changes made will be placed at the www.tryumf.com website or sent via e-mail to the Customers who have an Account.
    2. The current version is available at the Site and Store at www.tryumf.com.
    3. This Privacy Policy shall apply from July 01, 2018.