Privacy Policy


Pursuant to the provision of Article 13 of 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 (hereinafter: "RODO"), we inform about the manner and purpose for which Users' personal data are processed, as well as about their rights under RODO.

Administrator

The administrator of the personal data is COMEX S.A. with its registered office at Jesienna 21 Street, 80-298 Gdańsk, entered in the register of entrepreneurs kept by the REGISTRAR JUDGE GDAŃSK - PÓŁNOC IN GDAŃSK, VII ECONOMIC DEPARTMENT OF THE NATIONAL REGISTER OF JUDGMENTS, under the number 0000334933, NIP 5840203825, REGON 001261671 ("COMEX").  

Contact information: 

- address: 21 Jesienna St., 80-298 Gdansk 

- phone: 58 556 13 13 

- e-mail: info@comex.com.pl


The Privacy Policy sets out the rules for the processing of personal data obtained by us from persons visiting the https://b2b-eur.comex.com.pl website and using the services offered therein ("Users"), in particular those requiring registration or services concerning the purchase of goods on the b2b Platform, available at https://b2b-eur.comex.com.pl (the "Online Store"). This includes Entrepreneurs as defined in the General Terms and Conditions of the b2b-eur.comex.com.pl Online Store (the "Terms and Conditions"), as well as persons who have a Sub-account under the authority of Entrepreneurs, in this Online Store.

The Privacy Policy is intended to explain all issues concerning the processing of personal data in a fair, accessible and as clear as possible manner.


Purposes, grounds and duration of personal data processing

Users' personal data are collected in connection with registration for the selected service, in the case of communication with COMEX S.A., in particular in connection with placing orders in the Online Store and in the framework of processing complaints or using the contact form. COMEX S.A. guarantees that it will process Users' personal data only for specific, explicit and legally justified purposes. The purposes, legal basis and period of processing of personal data are indicated separately in relation to each purpose of data processing, in accordance with the following provisions containing a detailed description of the various purposes of data processing.    


PurposeLegal basis
Period of data processing

Entrepreneur's Account - in the Online Store.

As a rule, the services available at https://b2b-eur.comex.com.pl are aimed at businesses, and we encourage you to provide personal information only where it is actually necessary.

We may process Personal Data provided by you in connection with the registration of your Entrepreneur Account, but also other Personal Data collected in connection with your activity in the Online Store and use of our services (in particular, the name, surname, e-mail address and telephone number of a contact person; contact telephone number; invoice data, including address [if they allow identification of an individual], and in the case of Users running a sole proprietorship, company name and tax identification number [NIP]) are or may be processed for purposes related to the operation of your Entrepreneur Account in the Online Store.

Article 6(1)(b) of the RODO, i.e. the necessity for the performance of the contract you enter into by creating an Entrepreneur Account and accepting the relevant Terms and Conditions

Provision of Personal Data is voluntary, however, to the extent indicated in the registration form, it may be necessary in order to perform registration in the Online Store or other service requiring registration.  The Personal Data will be processed for the period necessary to perform the concluded agreement, i.e. until the chosen service is cancelled and the Entrepreneur's Account is deleted. This period may be extended, provided that there is a legitimate interest of the administrator to process your data for the defense of possible claims, for the period of their limitation or the processing will be required by the relevant law.

Order Processing

We may process your Personal Data in order to process your order and perform the concluded contract - in particular, to confirm its placement and reservation (if such option is available and you have chosen it) or to send the selected product to you or to a collection point, as well as to contact you about it.

Article 6(1)(b) of the RODO, i.e. the necessity for the performance of the sales contract you enter into after placing an order or a reservation contract (if such option is available and you have selected it);


Provision of Personal Data is voluntary, however, in some cases it may be necessary to place an order - in particular, if the purchaser is a sole proprietor or a contact person has been indicated;

In order to execute the order, we will process your data for the period of execution of the contract, as well as for the time required by law (e.g. tax, accounting).


Purposes pursued under the so-called legitimate interest of the data controller:

all activities in order to enable the User to place orders in the Online Store or to respond to a complaint, as well as to assert claims for orders placed 

Article 6(1)(f) RODO - legitimate interest of the administrator

- until the deletion of the Entrepreneur's Account, together with the Sub-Accounts, and then for 3 years to protect against possible claims, and to pursue claims against Entrepreneurs (including claims for payment for the delivery of Goods);

 - until a claim is answered, and then until the end of the calendar year in which the 6-year statute of limitations expires in order to protect against possible claims.

In the event that a dispute is pending or a proceeding is in progress, particularly a court proceeding, the retention period will be calculated from the date of the end of the dispute or the final conclusion of the proceeding.

Legal obligations 

In particular, for the purpose of issuing and storing invoices and accounting documents, as well as processing complaints and returns within the time and form specified in the regulations that apply to a specific category of User (e.g., Entrepreneur or consumer).

Article 6(1)(c) of the DPA, i.e. the necessity to fulfill a legal obligation of the Administrator

For the time required by law (e.g. tax, accounting).

Newsletter

The processing of personal data may take place in connection with the performance of the Newsletter contract through the selected communication channel and in accordance with the applicable Terms and Conditions.

Article 6(1)(a) RODO, i.e., consent

Until you withdraw your consent.


Source of obtaining personal data

COMEX S.A. processes personal data obtained directly from Users, provided while filling in the registration form in order to use the selected service or subscribe to the Newsletter, providing data in a complaint application , using the contact form or using any other form of contact with us. In addition, the data provided are verified with the information contained in state registers (Central Registration and Information on Business Activity or the Register of Entrepreneurs of the National Court Register).


Categories of personal data processed by COMEX S.A.

When filling out the registration form for a selected COMEX S.A. service, the scope of data determines the appropriate form. For some services a wider range of data may be required. Usually we require data concerning the company, however, we may collect the following categories of personal data, which may allow the identification of individuals:

  1. basic personal data (e.g. name and surname, name of conducted business),
  2. contact data (e.g. phone number, e-mail address, address of conducted business, address for delivery), 
  3. identification data (e.g. NIP, REGON, in case of commercial companies, also KRS),


In the case of communication using the contact form, COMEX S.A. processes the following categories of personal data:

  1. basic personal data (e.g. name and surname, name of conducted business), 
  2. contact data (e.g. phone number, e-mail address, address of conducted business, address for delivery), 
  3. identification data (e.g. NIP, REGON, in case of commercial companies, also KRS), 
  4. communication data (e.g. data of communication conducted with the User), 
  5. data concerning orders placed, dates and dates of payments,


Recipients of personal data

A data recipient within the meaning of the RODO is both an entity that processes personal data on behalf of COMEX S.A. and an entity to which the data is made available for its own purposes (e.g. public administration bodies). 

Recipients of Users' personal data may be:

  1. public authorities, institutions or third parties authorized to request access to or receive personal data on the basis of the law, 
  2. entities to which COMEX S.A. has entrusted the processing of personal data on the basis of concluded agreements, e.g. IT and other technology service providers processing data on behalf of COMEX S.A., suppliers and partners of logistics, transportation and delivery services, suppliers of Goods and parts for these Goods sold by COMEX S.A., 
  3. entities providing consulting, legal services.


Making automated decisions based on personal data, including profiling

COMEX S.A. does not process personal data in an automated manner that may result in automated decision-making, including decisions based on profiling.


Rights of data subjects

The data subject has the following rights:

  1. The right to request access to one's data, rectification, erasure or restriction of processing, 
  2. The right to object to processing, 
  3. The right to data portability, 
  4. The right to withdraw consent to the processing of personal data for a specific purpose, if the data subject has previously given such consent; however, withdrawal of consent does not affect the lawfulness of data processing prior to the withdrawal of consent, 
  5. The right to lodge a complaint to the supervisory authority in connection with the processing of personal data by COMEX S.A.: 

Urząd Ochrony Danych Osobowych

ul. Stawki 2, 00-193 Warszawa

kancelaria@uodo.gov.pl

The data subject may exercise his/her rights by contacting COMEX S.A. at: 21 Jesienna Street, 80-298 Gdańsk, or at e-mail address:  info@comex.com.pl .

COMEX S.A. guarantees the confidentiality of any personal data provided to it and ensures that all security and personal data protection measures required by personal data protection regulations are taken. Personal data are collected with due diligence and properly protected against access by unauthorized persons.  

Final provisions

The provisions of the Privacy Policy are subject to change or update, so we recommend that you follow the changes regularly. 

Questions related to the Privacy Policy should be sent to: 21 Jesienna Street, 80-298 Gdansk, or at e-mail:  info@comex.com.pl

Last modification date: 07.06.2024.

Information regarding online dispute resolution pursuant to Art. 14 Para. 1 of the ODR (Online Dispute Resolution Regulation):

The European Commission gives consumers the opportunity to resolve online disputes pursuant to Art. 14 Para. 1 of the ODR on one of their platforms. The platform (http://ec.europa.eu/consumers/odr) serves as a site where consumers can try to reach out-of-court settlements of disputes arising from online purchases and contracts for services.