Privacy policy
The following Privacy Policy sets out the rules of storing and accessing data on the Devices of the Users using the Service for the purpose of providing services electronically by the Controller and the rules of collecting and processing personal data of the Users, which were given by them personally and voluntarily through the tools available in the Service.

§1 Definitions

• The website – the “aunavegan.com” website operating at https://aunavegan.com.
• External service – websites of partners, service providers or recipients cooperating with the Controller
• Controller of the Service / Data – The Controller of the Service and the Controller of Data (hereinafter referred to as the Controller) is the company “Natural Anna Kościelnik”, operating at the address: ul. Słoneczna 18, Trzcianka 64-980, Poland, with a tax identification number (NIP): 763 205 22 07, providing services electronically through the Service
• User – a natural person for whom the Controller provides services electronically through the Service.
• Device – an electronic device with software, through which the User gains access to the Service
• Cookies – text data collected in the form of files placed on the User Device
• FAMILY – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals 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 – means information about an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as 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 an individual
• 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, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, deletion or destruction;
• Restriction of processing – means the marking of stored personal data in order to limit their future processing
• Profiling – means any form of automated processing of personal data which consists in using personal data to evaluate certain personal factors of an individual, in particular to analyse or forecast aspects of the individual’s performance, economic situation, health, personal preferences, interests, reliability, behaviour, location or movement
• Consent – the data subject’s consent means the voluntary, concrete, conscious and unambiguous demonstration of his or her willingness, to which the data subject gives his or her consent to the processing of personal data relating to him or her in the form of a statement or explicit confirmatory action.
• Personal data breach – means a breach of security leading to accidental or unlawful destruction, loss, modification, unauthorized disclosure or unauthorized access to personal data transmitted, stored or otherwise processed
• Pseudonymisation – means the processing of personal data in such a way that they can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is stored separately and is subject to technical and organisational measures which make it impossible to assign it to an identified or identifiable natural person
• Anonymisation – Anonymisation of data is an irreversible process of data operation which destroys / overwrites “personal data” making it impossible to identify or link a given record with a specific user or individual.

§2 Data Protection Inspector

On the basis of Art. 37 of the GCRL, the Controller has not appointed a Data Protection Inspector.
In matters concerning data processing, including personal data, you should contact the Controller directly.

§3 Types of Cookies

• Internal Cookies – files placed and read from the User’s Device by the Service’s ICT system.
• External Cookies – files placed and read from the User’s Device by the information and communication systems of External Services. Scripts of External Services, which may place Cookies on the User Device, have been intentionally placed on the Website through scripts and services made available and installed on the Website.
• Session cookies – files uploaded and read from the User’s Device by the Service during one session of a given Device. After a session, files are deleted from the User Device.
• Permanent Cookies – files placed and read from the User Device by the Service until they are manually deleted. Files are not deleted automatically after the end of the Device session unless the User Device configuration is set to delete cookies at the end of the Device session.


§4 Data storage security

• Mechanisms for storing and reading cookies – The mechanisms for storing, reading and exchanging data between the Cookies stored on the User Device and the Website are implemented through the built-in mechanisms of web browsers and do not allow the retrieval of other data from the User Device or data of other websites visited by the User, including personal data or confidential information. It is also practically impossible to transfer viruses, Trojan horses and other worms to the User Device.
• Internal Cookies – Cookies used by the Controller are safe for User Devices and do not contain scripts, content or information that may threaten the security of personal data or the security of the Device used by the User.
• External Cookie – the Controller performs all possible actions to verify and select service partners in the context of User safety. The Controller selects well-known, large partners with global social trust for cooperation. However, the Controller does not have full control over the content of the Cookie files from external partners. The Controller is not responsible for the security of the Cookie files, their content and their licensed use by the Scripts installed on the site, coming from external sites, as far as the law allows. The list of partners is presented in the further part of the Privacy Policy.
• Cookie file control
o The user can at any time change the settings for saving, deleting and accessing the data of the saved cookies by each website.
o Information on how to disable cookies in the most popular computer browsers can be found at: how to disable cookies or at one of the indicated providers:
– Managing cookies in Chrome browser
– Managing cookies in Opera browser
– Managing cookies in FireFox browser
– Managing cookies in your Edge browser
– Managing cookies in your Safari browser
– Managing cookies in Internet Explorer 11 browser
o The User may at any time delete any stored Cookie files using the tools of the User Device through which the User uses the Service.
• Threats on the part of the User – the Controller applies all possible technical measures to ensure the security of data placed in the cookies. It should be noted, however, that ensuring the security of this data depends on both parties including the user’s activity. The Controller does not take responsibility for intercepting this data, impersonating the User’s session or removing it, as a result of the User’s conscious or unconscious activity, viruses, Trojan horses and other spyware, which may be or was infected the User’s device. Users should follow the instructions for safe use of the network to protect themselves from these threats.
• Storage of personal data – the Controller ensures that he makes every effort to ensure that the processed personal data entered voluntarily by the Users are safe, access to them is limited and carried out in accordance with their purpose and purposes of processing. The Controller also ensures that he makes every effort to protect the data he possesses against their loss, by applying appropriate physical and organizational safeguards.
• Storage of passwords – The Controller declares that the passwords are stored in encrypted form, using the latest standards and guidelines in this area. It is practically impossible to decrypt the passwords given in the Service to access the account.


§5 Purposes for which Cookie files are used

• Streamlining and facilitating access to the Service
• Service Personalization for Users
• Enabling the Login to the service
• Marketing, Remarketing in external services
• Advertising serving services
• Affiliate services
• Keeping statistics (users, number of visits, types of devices, link, etc.)
• Serving multimedia services
• Provision of social services


§6 Purposes of personal data processing

Personal data voluntarily provided by the Users are processed for one of the following purposes:
• Implementation of electronic services:
o Services of registration and maintenance of the User’s account on the Website and the functionalities associated with it
o Newsletter services (including sending advertising content with consent)
o Services of commenting / liking entries in the Service without registering
o Services of sharing information about the content placed on the Service on social networking sites or other sites.
• Controller’s communication with Users in matters related to the Service and data protection
• To ensure the legally justified interest of the Controller
User data collected anonymously and automatically is processed for one of the following purposes:
• Statistical reporting
• Remarketing
• Serving ads tailored to users’ preferences
• Support for affiliate programs
• To ensure the legally justified interest of the Controller


§7 External Service Cookies

The Controller in the Website uses javascript and web components of partners, who can place their own cookies on the User’s Device. Remember that in the settings of your browser you can decide on your own what cookies are allowed to be used by particular websites. Below is a list of partners or their services implemented on the Site that may place cookies:
• Social / combined services:
(Registration, Login, content sharing, communication, etc.)
o Twitter
o Facebook
o Google+
• Content sharing services:
o Instagram
• Newsletter services:
o MailChimp
• Keeping statistics:
o Google Analytics
Services provided by third parties are beyond the Controller’s control. These entities may at any time change their terms of service, privacy policy, the purpose of data processing and the use of cookies.


§8 Types of data collected

The Service collects data about the Users. Part of the data is collected automatically and anonymously, and part of the data is personal data provided voluntarily by the Users when subscribing to particular services offered by the Service.
Anonymous data collected automatically:
• IP address
• Browser type
• Screen resolution
• Approximate location
• Opened subpages of the website
• Time spent on the appropriate subpage of the service
• Type of operating system
• Address of the previous subpage
• Address of the referring party
• Browser language
• Internet connection speed
• Internet service provider
Data collected during registration:
• First name / last name / pseudonym
• Login
• E-mail address
• Address of residence
• IP address (collected automatically)
Data collected during subscription to the Newsletter service
• First name / last name / pseudonym
• E-mail address
• IP address (collected automatically)
Data collected while adding a comment
• First and last name / alias
• E-mail address
• Web address
• IP address (collected automatically)
Some of the data (without identification data) may be stored in cookies. Some of the data (without identifying data) may be transferred to a statistical service provider.


§9 Access to personal data by third parties

As a rule, the only recipient of personal data provided by the Users is the Controller. The data collected within the framework of provided services are not transferred or resold to third parties.
Access to data (most often on the basis of an agreement of entrustment of data processing) may be granted to entities responsible for the maintenance of infrastructure and services necessary to run the service, i.e:
• Hosting companies, providing hosting or related services for the Controller
• Companies through which the Newsletter service is provided
• Companies intermediating in on-line payments for goods or services offered within the Service (in case of making purchase transactions in the Service)
• Companies responsible for delivering physical products to the User (postal / courier services in case of making purchase transactions in the Service)
Entrusting personal data processing – Newsletter
In order to provide the Newsletter service, the Controller uses the services of a third party – MailChimp, . The data entered in the newsletter subscription form are transferred, stored and processed by the external service provider.
Please be advised that the designated partner may modify the indicated privacy policy without the Controller’s consent.

Entrusting the processing of personal data – Hosting Services, VPS or Dedicated Servers
In order to run the service, the Controller uses the services of an external hosting provider, VPS or Dedicated Servers – H88 S.A. All data collected and processed in the service is stored and processed in the infrastructure of the service provider located in Poland. It is possible to access the data as a result of service work carried out by the service provider’s personnel. Access to this data is regulated by an agreement concluded between the Controller and the Service Provider.

Data processing for on-line payments
In the case of on-line payment execution, all data concerning the payment are transferred directly by the User to the entity executing the payment – PayPro S.A. at 15 Kanclerska Street, 60-327 Poznań, Poland. Selected data necessary to execute the transaction are then transferred by this entity to the Controller. The transfer of data is governed by an agreement concluded between the Controller and the Service Provider.

Transfer of personal data – Courier services
In case of concluding a transaction, which requires the transfer of the object, to which the transaction pertained, via mail or courier, a part of personal data of natural persons or data of natural persons conducting business activity is transferred to the entity providing postal / courier services for the Controller, selected by the User. The transfer of these data is governed by an agreement concluded between the Controller and the Service Provider.


§10 Method of personal data processing

Personal data provided voluntarily by the Users:
• Personal data will not be transferred outside the European Union, unless it has been published as a result of an individual action of the User (e.g. entering a comment or an entry), which will make the data available to every person visiting the service.
• Personal data will not be used for automated decision making (profiling).
• Personal data will not be sold to third parties.
Anonymous data (without personal data) is collected automatically:
• Anonymous data (without personal data) will be transferred outside the European Union.
• Anonymous data (without personal data) may be used for automated decision making (profiling).
The profiling of anonymous data (without personal data) does not have legal effect or similarly does not significantly affect the person whose data is subject to automatic decision making.
• Anonymous data (without personal data) will not be sold to third parties.


§11 Legal basis of personal data processing

The Service collects and processes Users’ data on the basis of:
• Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals 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)
o Article 6 (1) (a) the
data subject has consented to the processing of his/her personal data for one or more specified purposes
o Article 6(1)(b) processing
is necessary for the performance of a contract to which the data subject is a party or to take action at the request of the data subject before concluding a contract
o Article 6(1)(f) processing
is necessary for the purposes of legitimate interests pursued by the controller or by a third party
• Act of 10 May 2018 on personal data protection (Journal of Laws 2018, item 1000)
• Act of 16 July 2004. Telecommunication Law (Journal of Laws 2004 No. 171 item 1800)
• Act of 4 February 1994 on Copyright and Related Rights (Journal of Laws 1994 No. 24 item 83)


§12 Period of personal data processing

Personal data provided voluntarily by the Users:
As a rule, the indicated personal data is stored only for the period of Service provision within the Service by the Controller. They are deleted or anonymized within a period of up to 30 days from the end of service provision (e.g. deletion of the registered user account, deletion from the Newsletter list, etc.).
The exception is a situation which requires securing legally justified purposes of further processing of these data by the Controller. In such a situation, the Controller will store the indicated data, from the time the User requests their removal, for no longer than 3 years in the case of violation or suspected violation of the service regulations by the User.
Anonymous data (without personal data) is collected automatically:
Anonymous statistical data, not constituting personal data, are stored by the Controller in order to keep the service statistics for an indefinite period of time.


§13 Users’ rights related to personal data processing

The Service collects and processes Users’ data on the basis of:
• Right of access to personal data Users
have the right to obtain access to their personal data, realized upon request submitted to the Controller
• Right to rectify personal data Users
have the right to demand from the Controller to immediately rectify personal data that are incorrect and/or to complete incomplete personal data, executed upon request submitted to the Controller
• The right to delete personal data Users
have the right to demand from the Controller the immediate deletion of their personal data, realized upon request submitted to the Controller. In the case of user accounts, the deletion of data consists in the anonymisation of the data enabling the identification of the User. The Controller reserves the right to suspend the execution of the request to remove the data in order to protect the legally justified interest of the Controller (e.g. when the User has violated the Regulations or the data has been obtained as a result of the correspondence).
In case of the Newsletter service, the User has the possibility to delete his/her personal data
by using a link placed in each e-mail message sent.
• The right to limit the processing of personal data Users
have the right to limit the processing of personal data in the cases indicated in art. 18 of the TYPE, among others, questioning the correctness of personal data, carried out on request submitted to the Controller.
• The right to transfer personal data Users
have the right to obtain from the Controller personal data concerning the User in a structured, commonly used machine-readable format, executed upon request submitted to the Controller
• Right to object to the processing of personal data Users
have the right to object to the processing of their personal data in the cases specified in art. 21 of the GCRL, carried out upon request submitted to the Controller
• Right to lodge a complaintUsers
have the right to lodge a complaint with the supervisory body dealing with personal data protection.


§14 Contact to the Controller

You can contact the Controller in one of the following ways
• Postal address – Natural Anna Kościelnik, 18 Słoneczna Street, Trzcianka 64-980, Poland
• E-mail address – contact@aunavegan.com
• Telephone call – 0048-791-593-887
• Contact form – available at the address: /contact


§15 Service requirements

• Restricting the storage and access to cookies on your Device may cause some Service functions to malfunction.
• The Controller does not take any responsibility for malfunctioning functions of the Service in case the User limits in any way the possibility of saving and reading cookies.


§16 External links

In the Service – articles, posts, entries or comments of the Users may contain links to external sites with which the Service Owner does not cooperate. These links and the pages or files indicated under them may be dangerous for your device or pose a threat to the security of your data. The Controller is not responsible for the content outside the Service.


§17 Changes in the Privacy Policy

• The Controller reserves the right to change this Privacy Policy at any time without informing the Users about the use and enjoyment of anonymous data or the use of cookies.
• The Controller reserves the right to change this Privacy Policy on the processing of Personal Data at any time, of which he will inform the Users who have user accounts or are subscribed to the newsletter service by e-mail within 7 days from the change of subscriptions. Further use of the services means that the Controller has read and accepts the changes to the Privacy Policy. In case the User does not agree with the introduced changes, he is obliged to remove his account from the Service or unsubscribe from the Newsletter service.
• The introduced changes in the Privacy Policy will be published on this subpage of the Website.
• The introduced changes shall enter into force upon their publication.